Philadelphia Fire Department Exposure Control Plan

• The Philadelphia Fire Department Exposure Control Plan (ECP) provides guidelines to protect members' health in compliance with federal, state, and local laws.
• The ECP aims to reduce employee exposure to infectious materials, protect patients from infection, and addresses bloodborne pathogens and airborne/droplet transmitted diseases
• The ECP will be reviewed annually in December to reflect changes in procedures, policies, or work rules.
• Non-employees like students and ride-alongs must acknowledge in writing that they understand the ECP's regulations, and they are covered for post-exposure medical follow-up, but they are responsible for the costs.
• The guidelines cover reporting occupational exposures to various infectious agents, based on recommendations from organizations like the CDC, NIOSH, OSHA, and NFPA 1581.
• The guidelines also cover how to report an actual or perceived occupational exposure based on Federal, State and local laws.
• General guidance for Officers and members details reporting of actual/perceived occupational exposures, respective roles in prevention/management, post-exposure management (PEP), and when to notify the Infection Control Officer (ICO).
• Members must understand and familiarize themselves with all sections of the ECP and appendices.
• All members of the Philadelphia Fire Department are responsible for their physical and mental health.
• Members should follow infection control practices, participate in training, report communicable illnesses to the ICO, and get recommended immunizations.
• Missed appointments without valid excuses may lead to disciplinary action.
• The PFD's Infection Control Officer (ICO) obtains health histories, verifies immunity, and provides/arranges vaccinations for healthcare personnel, as recommended by the CDC.
• The PFD Infection Control Officer also monitors advisories, alerts, and updates from the CDC, Pennsylvania Department of Health, and city divisions regarding infectious diseases.
• The PFD Infection Control Officer provides methods to reduce infection transmission between patients and healthcare personnel (HCP).
• The PFD Infection Control Officer monitors and investigates potential infectious exposures and outbreaks among personnel.
• A baseline TB skin test (PPD) is provided at hire, with annual tests based on TB incidence in Philadelphia.
• The PFD offers Hepatitis B vaccinations to new hires within 10 days of assignment, as per CDC guidelines.
• Active members are offered the opportunity to complete the Hepatitis B vaccination series if required.
• Any member can decline the Hepatitis B vaccine by signing a form, but can receive it later at no cost.
• The PFD complies with employment screening guidelines under Act 115 of 2001.
• Firefighter, Paramedic and EMT candidates with conditional appointments will be screened for Hepatitis C during the pre-employment physical.
• The PFD follows ADA regulations regarding non-discrimination for members exposed to contagious diseases.
• The PFD ensures all personnel maintain personal protective equipment (PPE), engineering controls, and equipment necessary to maintain member safety.
• Viruses and bacteria are the microorganisms most commonly responsible for the spread of disease.
• Infectious diseases result from the invasion of a host by organisms like bacteria, viruses, fungi, or parasites.
• A communicable disease can be transmitted between individuals, and primary infection control concerns communicable diseases.
  • Salmonella is a highly infectious disease; however, salmonella is not contagious
  • Chickenpox is an infectious disease, which is also communicable; it can be easily transmitted from one person to another.
• Communicable diseases can spread either directly or indirectly.
• Direct transmission occurs through immediate contact with an infected person's blood or body fluids.
• Indirect transmission occurs through contact with blood/bodily fluids after it has passed to another person or object.
• Communicable diseases can be bloodborne or airborne.
• Bloodborne diseases, such as HIV, Hepatitis B (HBV), and Hepatitis C (HCV), are spread via blood or body fluids.
• Airborne diseases, such as TB and chickenpox, spread through the air.
• Assessing the risk of contracting a disease involves considering the type of exposure and factors like communicability, dosage, virulence, and host resistance.
• Communicability is the ability of a disease to be transferred between hosts.
• Dosage is the number of viable organisms received during exposure; different illnesses need different amounts of infectious agents to cause infection.
• A single Hepatitis B virus in one milliliter of blood may be all that is needed to spread the infection, while 100,000 HIV viral particles may be needed
• Virulence is the power of an organism to cause disease; it depends on its strength or ability to overcome bodily defenses.
• HIV dies when exposed to light or air, while the Hepatitis B virus has been shown to live on a surface from days to weeks and still be infectious if it enters the blood stream.
• Host resistance involves the body's ability to fight infection, which depends on its normal defense mechanisms.
• PFD personnel who suspect exposure through contact with blood, specified body fluids or airborne droplets must contact the ICO as soon as possible, or within 2 hours of the incident.
• The ICO can be reached at (215) 686-1338 during business hours or (215) 906-3002 on nights, weekends, and holidays, if there is no answer contact the FCC Supervisor.
• Notification to the ICO should be early and of paramount importance to determine the significance of the exposure ensuring the opportunity to obtain source patient blood.
• If unable to contact ICO directly, a designee may call with specific exposure details.
• The designee must understand confidentiality.
• The ICO documents the facts as stated by the member and makes a determination as to whether a reported exposure meets the criteria for a significant exposure based on CDC guidelines.
• Significant exposures are evaluated at Jeanes Business Health during business hours (0800-1700), and at Jeanes Emergency Department after 1700 hours, weekends, and holidays.
  • (7600 Central Avenue, Phila, Pa 19111)
• Members needing evaluation/treatment are directed to Jeanes by the ICO, traveling via Fire Department apparatus or private vehicle based on ICO determination.
• Members directed to Jeanes must maintain contact with the ICO via cell phone.
• The ICO makes all necessary notifications, including to the FCC Supervisor to get a "name withheld" injury number.
• The ICO handles all exposure-related paperwork, fax transmittals, and follow-up coordination.
• Members evaluated/treated at Jeanes Hospital return to their assignment to complete their shift.
• Unless specified otherwise by a Jeanes Physician
• Members evaluated in Jeanes Emergency Room report the next business day to Jeanes Business Health.
• Members who have an exposure must document the details of the incident immediately following post exposure evaluation.
  • Member exposed is responsible for this document.
• Airborne/aerosolized exposures require the medical facility to notify the ICO as soon as possible (within 48 hours) upon determining a patient has an airborne infectious disease.
• Exposure risk is determined by the ICO based on CDC guidelines.
• Infestations are handled as directed by EMS Procedure #14.
• After exposure, members must complete initial first aid by cleaning the area with soap and water, and flushing mucous membranes.
• ICO completes an exposure report with details and the source individual's identity, all is kept confidential.
• If "significant exposure" determined by physician, the ICO arranges for the source individual tested for Hepatitis B (HBV), Hepatitis C (HBC), and rapid HIV. Testing is not repeated if source is known to be infected.
• Results of the source individual's testing will be made available to the exposed member, and provided laws/regulations concerning identity/status disclosure.
• The member’s blood shall be collected and tested for HBV, HBC, and HIV after consent is obtained. When a member does not consent to testing, the physician shall document such withholding of consent.
• Post-exposure prophylaxis is available as medically indicated and recommended by the CDC.

Counseling and Compliance

• Counseling is available, including informing the member and his/her family about medical conditions resulting from exposure and treatment and evaluation of illness.
• Compliance to all exposure evaluations, treatment and follow-up visits will be enforced by the ICO and followed by the member.

Engineering and Work Practice Controls

• Members in rescue, firefighting, hazmat, and EMS may be exposed to blood/infectious materials.
• All members will utilize standard precautions to prevent contact with blood and other potentially infectious materials. All body fluids shall be considered potentially infectious materials.

Standard Precautions

• Gloves must be worn when in contact with blood, bodily fluids, mucous membranes, or non-intact skin, when handling soiled items, and when cleaning soiled surfaces.
• Gloves are disposed of and hands washed after each patient or use for cleaning or handling infectious material.
• Members must wash hands and exposed skin with soap and water or flush mucous membranes with water as soon as possible.
• Hands should be washed for at least 15 seconds after removing gloves, before eating/preparing food, and after contact with body fluids, mucus membranes, or broken skin.
• Antiseptic towelettes or hand cleansers are used when hand washing isn't possible, followed by soap and water when available.

Contact

• Skin, mucous membranes, or body areas that come into contact with potentially infectious materials should be washed as soon as possible.
• Perform all procedures involving blood or OPIM to minimize splashing and splatter.
• Members must utilize appropriate engineering and work practice controls to minimize occupational exposure risks. Approved infection control PPE must prevent blood or infectious materials from reaching the member's clothing, skin, eyes, mouth, or mucous membranes.
• The Department provides disposable gloves, gowns/coveralls, eye shields/face masks/goggles, bag-valve masks (BVMs), pocket masks, antiseptic hand sanitizer, and biohazard bags as PPE.
• All PPE must be removed/disposed of in biohazard containers, and removed before entering vehicle cab or driver's compartment.
• Disposable gloves are changed after each patient contact or if damaged during treatment.
• Structural firefighting protective clothing must be worn on incidents, with disposable gloves underneath when encountering infectious materials (e.g., vehicle extrication), except when there is exposure to extreme heat.
• If a BVM is unavailable, use a pocket mask with a one-way valve for oral rescue breathing.
• Members must wear eye shields/face masks/goggles when splashes, spray, or droplets of blood or infectious material may occur.
• Masks are required if an individual is suspected of having an airborne transmissible disease (N95 masks).
• Use a surgical mask on the patient.
• Gowns/coveralls should be worn during procedures which are likely to generate splashes of blood or other potentially infectious material.

Handling Sharps

• Needles will not be re-capped with two hands, broken, bent, broken by hand, cut, sheared or otherwise manipulated by two hands.
• Such bending, re-capping or needle removal must be accomplished through the use of a mechanical device (forceps, dust pan and brush) or one-handed technique.
• Breaking sharps is strictly prohibited by the PFD.
• Do not tamper with safety mechanisms on sharps designed to prevent needlestick injuries.
• Dispose of all sharps immediately after use in puncture-resistant, leak-proof biohazard containers.
• Never insert sharps into bench seat cushions, carpets, mattresses, or other permanent fixtures with soft cushions.

Broken Glass

• Never pick up broken class with hands.
• Pick up contaminated broken glass/sharps with mechanical means (forceps, dust pan, brush) and place in sharps container.
• Members are not permitted to open, empty, or reach into a sharps container.
• Full sharps containers must be closed, sealed with tape, and properly disposed of.

Cleaning & Decontamination

• Emergency response vehicles contaminated by airborne, bloodborne, or infectious materials shall be cleaned and decontaminated ASAP.
• Work surfaces should be cleaned with warm water and soap, then disinfected with bleach solution.
• Patient care equipment must be cleaned and disinfected, or be disposed of if its disposable.
• All infection control PPE should be disposed of.
• All personal work uniforms/accessories that become contaminated with blood or other infectious material must be cleaned and disinfected by the member.
• Disposable contaminated materials must be placed in double red bags in an appropriate biohazardous infectious waste container.
• Biohazard waste material shall be disposed of at of ne of the nine designated biohazard waste sites.
• Red bags are only for biohazardous waste and must be placed into a clearly marked biohazard container during handling, storage, and transport to prevent leakage/spills.
• Sharps containers must be closed, sealed, labeled as biohazard, and kept upright, replacing them when they are 3/4 full.
• Contaminated Bunker Gear should be placed in a red biohazardous bag then a black trash bag, then contact the Safety Office.
• No food/drink on countertops, bench seats, or areas with blood/OPIM.
• Each workplace needs a written schedule for cleaning/decontamination for members not exposed to blood/OPIM.
• HIV and Hepatitis C are fragile and die quickly, but Hepatitis B can live on stainless steel for up to 7 days in dried blood.
• Contaminated/biohazardous waste must not be disposed of at a non-designated biohazard waste site.*

Training

• Training is provided at initial hire and annually, the ICO can require additional training as needed.
• Annual training covers diseases, department policy/procedure changes, and exposure rates.
• Training includes topics on bloodborne and airborne diseases, transmission modes, ECP information access, and the potential blood/infectious materials exposure, and PPE usage.
• Training also covers procedures to follow after an exposure incident, including reporting and medical evaluation.
• Opportunity to ask questions about this ECP.

Recordkeeping

• The ICO is responsible for maintaining members' exposure records.
• The ICO keeps accurate medical records for all members who incur an occupational exposure, including name and payroll number.
• A copy of vaccination status, examinations, follow-up results, procedures, and exposure incidents are also included in the medical records.
• The ICO keeps medical records confidential, only disclosing with express written consent or when legally compelled.
• Medical records are kept as per Title 29 CFR Sections 1910.20 and 1910.1030
• The ICO maintains a Sharps Injury Log with the type/brand of device, incident location, and explanation.
• The ICO also keeps training records with dates, trainer info, member names/titles, and subject matter.
• Training records must be provided to members upon request and maintained for five years after the training date.