Elements of the Morningside Campus Bloodborne Pathogens Program

Appendices

Appendix A: Columbia University Morningside Campus Emergency Procedures
Appendix B: Hepatitis B Vaccine Notification Form
Appendix C: Morningside Campus Exposure Control Plan
Appendix D: Definitions

History of Standard

The OSHA Bloodborne Pathogens standard is designed to protect the nation's workers, particularly health care workers, from exposure to the Hepatitis B Virus (HBV), the Human Immunodeficiency Virus (HIV), and other bloodborne pathogens. Of the diseases caused by these viruses, Hepatitis B is the most common, with 8,700 cases per year among workers in the health care profession. Hepatitis B infection may result in serious illness, potential long-term disability and death. HIV causes AIDS, for which there currently is no cure and which eventually results in death. These viruses, as well as other organisms that cause bloodborne diseases, are found in human blood and certain other human body fluids. Therefore, employers have a responsibility to ensure that workers do not come into direct contact with blood or other potentially infectious materials while performing their jobs.

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Morningside Campus Responsibilities

EH&S

Department Heads/Employee Supervisors

Employees

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Exposure Control Plan

The Columbia University Exposure Control Plan (ECP) is a written program that outlines the protective measures that will be implemented to eliminate or minimize employee exposure to blood and OPIM (See Appendix C). The ECP also states the Morningside Campus job categories considered potentially at risk for occupational exposure.

EH&S will review the ECP and update it on an annual basis, unless changes in the workplace occur.  In that case, the plan will be assessed and updated immediately to accommodate workplace changes.  Copies of the Morningside Campus Exposure Control Plan will be kept in the EH&S office and will be available to all Morningside Campus employees.

Standard Precautions

Standard Precautions, formerly referred to as Universal Precautions, refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids be treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. The Morningside Campus will adopt and implement the use of Standard Precautions whenever handling any human blood or OPIM.

In addition, it is important to note that this policy is intended to serve as a supplement to procedures already in place such as; routine hand washing and utilization of protective gloves to preclude exposure to blood or OPIM.  Standard Precautions are intended to prevent parenteral, mucous membrane, and non-intact skin exposures of workers on the Morningside Campus to bloodborne pathogens by providing proper awareness training and protective equipment.

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Exposure Incidents

An exposure incident is defined as skin, eye, mucous membrane, or parenteral contact with blood or OPIM that has resulted from the performance of the employee's duties. 

In the event of an exposure incident, the affected employee must immediately seek medical attention.  The employee's supervisor should be notified as soon as possible.  The employees supervisor should contact the EH&S office who will conduct an investigation, and will make recommendations as to how to avoid future events.

Post Exposure Evaluation and Follow Up Procedures

In the event a Morningside Campus employee is exposed to blood or OPIM, the following procedures will be followed:

Counseling Following an Exposure Incident

Post-exposure counseling will be conducted by Health and Related Services.  The counseling will address issues such as; refraining from blood, semen, or organ donation; abstaining from sexual intercourse or using measures to prevent HIV transmission during sexual intercourse; and refraining from breast feeding infants during the follow-up period.

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Follow Up Examination

The employee will be sent to John Jay Health and Related Services where laboratory tests will be conducted by the laboratory at no cost to the employee. The follow up examination will include a confidential medical evaluation documenting the circumstances of exposure, identifying and testing the source individual if feasible, testing the exposed employee's blood if he/she consents, post-exposure prophylaxis, counseling and evaluation of reported illnesses. 
The healthcare professional conducting the examination will be provided with specific information to facilitate the evaluation and their written opinion on the need for hepatitis B vaccination following the exposure. Information such as the employee's ability to receive the hepatitis B vaccine will be supplied to the employer. All diagnoses will remain confidential.

Hepatitis B Vaccinations

Hepatitis B Virus (HBV) causes an infection of the liver. Symptoms of HBV infection may range from none to flu-like symptoms, jaundice and serious illness. If symptoms do occur, they may not be evident until 2 to 6 months after the person is infected.  Infection with HBV can lead to chronic diseases later in life, such as cirrhosis and liver cancer and death.

Hepatitis B can be transmitted in many of the same ways as HIV - parenteral and mucous membrane exposures to infected body fluids. It can also be spread perinatally and through sexual intercourse.

The best way to prevent HBV infection is:

A few key points to remember:

All Morningside Campus employees, who have the potential for occupational exposure to blood or OPIM, will be offered the Hepatitis B vaccination series within 10 working days of assignment, at no cost. These vaccinations will be administered by Health and Related Services during the employees workshift.  The vaccinations will be administered under the supervision of a licensed physician/licensed healthcare professional and according to the latest recommendations of the U.S. Public Health Service (USPHS).

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Morningside Campus Hepatitis B Vaccination Procedures

All hepatitis B vaccinations will be provided by the Morningside Campus Office of Health and Related Services located in John Jay Hall.  Only those employees identified as exposed to blood or OPIM will be authorized to receive vaccination. 

All identified employees will receive the HEPATITIS B VACCINE NOTIFICATION FORM (see Appendix B.  If the employee elects to receive the vaccinations he/she will return the completed form to their departmental office.  The departmental office will notify Health and Related Services of how many people have elected to receive the vaccinations and will schedule the appointments.

Upon receiving the first of three vaccinations, Health and Related Services will issue a vaccination card, which will remind the employee of the next vaccination. 
Upon completing all three vaccinations, the employee will keep a copy of the completed vaccination card.  In addition, the departmental office and EH&S will also receive and maintain copies of the completed vaccination cards.

Hazard Communication

All aspects of the Columbia University Hazard Communication Program will be implemented when handling blood or OPIM.  This will include the proper use of labels and employee awareness training.  Employees will be trained to recognize potential exposure situations and how to protect themselves through the proper use of engineering controls and PPE.

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Labels

Warning labels that include the universal biohazard symbol, followed by the term "biohazard," will be included on bags/containers of contaminated laundry, on bags/containers of regulated waste, on refrigerators and freezers that are used to store blood or OPIM, and on bags/containers used to store, dispose of, transport, or ship blood or OPIM (e.g., specimen containers). In addition, contaminated equipment which is to be serviced or shipped will have a readily observable label attached which contains the biohazard symbol and the word "biohazard" along with a statement relating which portions of the equipment remain contaminated.

Employee Information and Training

Bloodborne Pathogens Training will be conducted by EH&S on an annual basis. Those employees who have received appropriate training at the time of first employment and thereafter, will only receive additional training in items not previously covered. The training will cover the regulatory text of the standard and explanation of its contents, a general discussion on bloodborne diseases and their transmission, the specifics of the Morningside Campus exposure control plan, engineering and work practice controls, personal protective equipment, hepatitis B vaccine procedures, response to emergencies involving blood, how to handle exposure incidents, the post-exposure evaluation and follow-up program, and signs/labels/color-coding. In addition, the employees will be given a chance to ask questions.  Laboratory workers will receive additional site specific training.

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Recordkeeping

All medical records regarding occupational exposures will be kept on file in the EH&S office.  These files will be kept for each employee and will be maintained for the duration of employment plus 30 years.  In addition, all records will remain confidential and will include the employees name and social security number; hepatitis B vaccination status (including dates); results of any examinations, medical testing and follow-up procedures; a copy of the healthcare professional's written opinion; and a copy of information provided to the healthcare professional. All training records will be maintained for three years and will include the dates of training, contents of the training program, trainer's name and qualifications, names and job titles of all persons attending the sessions. All training records will be kept on file in the EH&S office.

All occupational bloodborne pathogens exposure incidents, (e.g., needlesticks, lacerations, splashes), will be recorded on the OSHA 200 log kept in the Office of Risk Management as an injury if:

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Appendix A - Columbia University Morningside Campus Emergency Procedure

The following Emergency Procedures are for the Columbia University Morningside Campus community only.  Columbia University personnel should contact Columbia University Morningside Security for the following emergency situations Medical, Fire, Criminal Activity, Chemical Spill, or Radioactive Spill at:

x 99 (On Campus)
854-5555 (Off Campus)

For non-emergency issues please contact the Environmental Health and Radiation Safety office during normal office hours Monday through Friday 9:00 a.m. to 5:00 p.m. at 854-8749.

After normal hours, weekends, and holidays please contact the CU Security Office.

Appendix B - Hepatitis B Vaccine Notification Form

Click on a link for the Hepatitis B Vaccine Notification (HTML / PDF / WORD)

Appendix C - Morningside Campus Exposure Control Plan

Morningside Employees Potentially at Risk
The employees currently identified as being potentially at risk on the Morningside Campus include:

This list may change if other Morningside occupations are identified.

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Procedures

The following are general procedures that will be followed during any task with potential for exposure.

Control Methods

Engineering Controls is the term that refers to controls (e.g., sharps disposal containers, needleless systems, self-sheathing needles) that isolate or remove the bloodborne pathogens hazards from the workplace.  All feasible engineering control methods will be implemented to reduce employee exposure.

Personal Protective Equipment (PPE)

Personal Protective Equipment (PPE) will be utilized as a barrier between the employee and blood or OPIM.  At a minimum, those employees identified as being at risk will always be wearing gloves provided by their supervisor and safety glasses with side shields or goggles. The employees supervisor, in coordination with EH&S, will provide, at no cost to the employee, PPE such as gloves and safety glasses/goggles. All of these safety items will be replaced as necessary to ensure an adequate supply is always on hand. The financial responsibility for repairing, replacing, cleaning, and disposing of PPE will be that of the employees department.

All contaminated sharps shall be disposed of in red sharps containers.  These containers will be supplied by the EH&S office upon request.  The EH&S office will regularly perform waste pick-ups.  All disposal of sharps and other red bag waste will be coordinated through EH&S.  

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PPE Selection Procedures

Sterile surgical gloves will be provided whenever an employee must handle blood or OPIM contaminated material.  All gloves used shall be thrown away in red bag receptacles immediately after use.  These gloves will not be washed or disinfected for reuse.  General purpose gloves (i.e. rubber household gloves) will be used for housekeeping chores involving the potential for contact with blood or OPIM.  Hypoallergenic gloves, glove liners, powderless gloves or other similar alternatives will be provided for employees who are allergic to the gloves that are normally provided.

To prevent exposure of mucous membranes of the mouth, nose and eyes, masks and protective eyewear (i.e. safety glasses or goggles) shall be worn for procedures that are likely to generate droplets or splashes of blood or OPIM.

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Handwashing Procedures

Latex Allergy

Latex gloves have proved effective in preventing transmission of many infectious diseases. But for some workers, exposures to latex may result in allergic reactions. Reports of such reactions have increased in recent years.

Latex allergy is a reaction to certain proteins in latex rubber. The amount of latex exposure needed to produce sensitization or allergic reaction is unknown. Mild reactions may involve respiratory symptoms such as runny nose, sneezing, itchy eyes, scratchy throat, and asthma. Rarely, shock may occur; however, a life threatening reaction is seldom the first sign of latex allergy.

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Tips on preventing latex allergy:

Preventing Needlesticks

All Morningside employees will take precautions to prevent injuries by needles, scalpels, and other sharp instruments or devices.  To prevent needlestick injuries, contaminated needles shall not be recapped, purposely bent or broken by hand, removed from disposable syringes, or otherwise manipulated by hand. 

After they are used, disposable syringes and needles, scalpel blades, and other sharp items shall be placed in the provided sharps containers. 

When emptying trash receptacles the following procedures should be implemented to reduce needlesticks:

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Spill Clean Up Procedures

If there is a spill of human blood or OPIM, the spill situation must be addressed immediately.  The EH&S office should be notified immediately.  If the appropriate PPE and spill clean up materials are present, and the employee has received the Bloodborne Pathogens training, he or she may contain and clean up the spill if it will not jeopardize his or her health or those in areas of close proximity.  EH&S will coordinate all spill clean up procedures. 

Any sharps material involved in the spill (i.e. broken glass, syringes, etc), shall be carefully removed.  Sharps will be placed in a sharps container.  Once the sharps material have been removed, the spill will be cleaned up.  The spill area shall be washed thoroughly with a fresh made bleach solution or other appropriate disinfectant.

Any equipment used to clean up spills (i.e mops, etc) must be either decontaminated with the appropriate germicide or disposed of properly

Sharps Containers

Sharps Containers provided will be:

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Each sharps container will be labeled with the universal biohazard symbol and the word "biohazard", or be red in color. Sharps containers shall be maintained upright throughout use, replaced routinely, and not be allowed to overfill when removing sharps containers from the area of use, the containers shall be:

Reusable containers shall not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of percutaneous injury.

Location of Sharps Containers

Sharps containers will be made easily accessible to employees and located as close as feasible to the immediate area where sharps are used or can be reasonably anticipated to be found.

Biohazard Labels

All areas which contain biohazards agents: refrigerators, sharps containers, storage areas must be labeled with a biohazard warning label. It must be red or orange in color with a biohazard symbol and lettering in black as illustrated below:

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Regulated Waste Disposal

EH&S will coordinate the disposal of all regulated waste.  In addition, EH&S Hazardous Waste Manager will make the determination as to whether or not a waste shall be classified as regulated waste.  Disposal of all regulated waste will be in accordance with applicable regulations of the United States, States and Territories, and political subdivisions of States and Territories.

Appendix D - Definitions

Blood - Defined as human blood, human blood components, and products made from human blood.

Bloodborne Pathogens - Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), and the Human Immunodeficiency Virus (HIV).

Contamination - Contamination refers to the presence or reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.

Contaminated sharps - Any contaminated object that can penetrate the skin including, but not limited to needles, scalpels, broken glass, broken capillary tubes, and plasticware.

Decontamination - The use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item. As a result, the surface or item is no longer capable of transmitting infectious particles and the surface is rendered safe for handling, use or disposal.

Engineering Controls - Mechanical devices that isolate or remove the bloodborne pathogens hazard from the workplace. Includes sharps containers, shielding, or self-sheathing needles.

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Good Samaritan Acts - Good Samaritan acts, such as helping a fellow worker with a nosebleed or cut finger, are not considered official duties or exposures covered under this plan.

Occupational Exposure - Defined as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of the employee's duties."

Other Potentially Infectious Materials (OPIM) - Defined as the following human body fluids: saliva in dental procedures, semen, vaginal secretions, cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV- containing culture media or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Parenteral - Piercing of mucous membranes or the skin through such events as: needlesticks, human bites, cuts, and abrasions.

Regulated Waste - refers to the following categories of waste which require special handling at a minimum; (1) liquid or semi-liquid blood or OPIM; (2) items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed; (3) items that are caked with dried blood or OPIM and are capable of releasing these materials during handling; (4) contaminated sharps; and (5) pathological and microbiological wastes containing blood or OPIM.

Seroconversion - The development of detectable specific antibodies in the serum as a result of infection or immunization.

Standard Precautions - An approach to infection control. According to the concept of Standard Precautions, all human blood and all human body fluids are treated as if infectious.  Formerly referred to as Universal Precautions.