Methods of
Implementation and Compliance
of Occupational Exposure Prevention Plan

Standard precautions are OSHA’s required methods of control to protect employees from exposure to all human blood and other potentially infectious materials. This concept requires that all human blood and other potentially infectious materials be treated as if known to be infectious for HIV, HBV, Hepatitis C virus or other blood-borne pathogens, regardless of perceived low risk status of a patient or patient population.

The Kentucky Department for Public Health recommends the use of standard precautions for all patients. Therefore, the use of protective barriers is recommended when performing tasks involving contact with blood, bodily fluids, non-intact skin and mucous membranes.

Standard precautions for health care workers may be summarized by the following principals:

• Treat all blood and bodily fluids as being potentially infectious.

• Use a barrier appropriate for the interaction. Protective barriers must be appropriate for the type of exposure anticipated.

• Do not bend, break, shear or recap needles. Needles must not be removed from disposable syringes. Disposable needles, syringes and other sharps must be placed in sharps  containers for disposal. The containers are to be located as close as practical to the area in which the items were used.

• Wash hands thoroughly before and after patient care, and between patients or sites on the same patient.

• Clean up blood and bodily fluid spills immediately. Use the NKY Health’s procedure: Decontamination of Blood/Bodily Fluid Spills.

• Follow nationally published guidelines for sterilization, disinfection, housekeeping and waste disposal.

• Keep mouthpieces and resuscitation equipment readily available if use is likely.

• Refrain from patient care when the health care worker has weeping dermatitis or exudative lesions.

• Additional isolation precautions (transmission–based precautions) may be necessary for patients with an infection transmissible by the airborne route (such as tuberculosis, varicella and measles), droplet route or contact route.

The revision of the bloodborne pathogens, needle sticks and other sharps injuries standard requires the employer to institute engineering and work practice controls as the primary means of eliminating or minimizing employee exposures. The primary agents of concern in current occupational settings are HBV, HCV and HIV. Engineering controls have been modified to include “safer medical devices, such as sharps with engineered sharps injury protections and needle-less systems.”

The revised standard reflects how employers implement new developments in exposure control technology. The revision requires employers to:

• Solicit input from non-managerial (frontline) health care workers to:

  • Identify, evaluate and select safety engineered sharp devices.

  • Identify proper work practices. 

• Reflect in the exposure control plan:

  • Changes in engineering controls

  • New or modified tasks or procedures which affect occupational exposure

  • Changes in technology that eliminate or reduce exposure to BBP

  • Review of commercially available and effective safety devices to eliminate or reduce occupational exposure.

This exposure control plan will be reviewed and updated annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure.

The Plan must document the engineering controls put into place by the employer and must document engineering controls’ effectiveness to eliminate or minimize needlesticks and other sharp injuries. The exposure plan must demonstrate the procedure used to decrease or eliminate exposures.  One example is the the formal evaluation, as coordinated by the Employee Health Nurse, of new safety engineered sharps devices for potential use by NKY Health and its staff.

The Employee Health Nurse is designated by the NKY Health to be responsible for annual review (update as needed) of this Exposure Control Plan.

The Clinic Manager of each health center will establish and maintain a log for percutaneous injuries from contaminated sharps in his/her health center. This log will be kept on a calendar year.

• With the exception of the bloodborne pathogens standards revisions effective April 18, 2001, the specifications of this subsection will be observed by NKY Health staff and will be reviewed as part of the annual program/service planning process.

• NKY Health will provide hand washing facilities which are readily accessible to staff .

• When conducting clinics or performing services at sites in the home or outside a health center where hand washing is not available, NKY Health will provide either antiseptic towelettes or an appropriate antiseptic hand cleanser along with clean cloth/paper towels. When antiseptic hand cleansers or towelettes are used, hands will be washed with soap and water when the staff returns to a place where hand washing facilities are available.

• NKY Health will instruct staff to wash their hands immediately, or as soon as feasible, after removal of gloves or other personal protective equipment.

• NKY Health will ensure that staff wash hands and any other skin with soap and water, or flush mucous membranes with water immediately, or as soon as feasible, following contact of such body areas with blood or other potentially infectious materials. Eyewash stations are provided at each NKY Health location.  (See "Emergency Eyewash Stations" subsection in the Worksite Emergency Plan (Evacuation) section of this Safety Manual for a list of the locations of eyewash stations.

• Contaminated needles and other contaminated sharps will not be bent, recapped or removed from an attached device unless the employee can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. Recapping or needle removal must be accomplished through the use of a mechanical devise or a one-handed technique. Shearing or breaking of contaminated needles is prohibited. Employees giving care in the home should instruct patients and/or caregivers of the need to use puncture resistant containers for the disposal of contaminated needles or other contaminated sharps.

• Eating, drinking, smoking, applying cosmetics or lip balm and handling contact lenses are prohibited for employees while in the patient care area or while giving care in a patient’s home where there is a reasonable likelihood of occupational exposure to potentially infectious materials.

• Food and drink will not be kept in refrigerators, freezers, shelves, cabinets, on counter tops or where other potentially infectious materials are present.

• All procedures involving blood or other potentially infectious materials will be performed in such a manner as to minimize splashing, spraying, spattering and generation of droplets.

• All blood draws must be done in the lab or in a room with tile or hard surface flooring.

• Mouth pipetting/suctioning of blood or other potentially infectious materials is prohibited.

• Equipment which may become contaminated with blood or other potentially infectious materials will be examined prior to servicing or transporting and will be decontaminated and cleaned as necessary unless NKY Health can demonstrate that decontamination of such equipment or portions of such equipment is not feasible. The following will also be completed:

  • A readily observable label will be attached to the equipment stating which portions remain contaminated.

  • NKY Health will ensure through training and education of staff that appropriate precautions are taken prior to use of or contact with the equipment by employees, the servicing representative and/or the manufacturer prior to handling, servicing, transporting to another facility or shipping.

• Specimens of potentially infectious materials will be placed in a container which prevents leakage.

• Sharps containers will be used for the disposal of contaminated needles and other sharps.

• Safer needle devices with engineered sharps injury protection are provided for venous blood access, capillary blood access, subcutaneous, intramuscular and intradermal injections.