Exposure Control Plan.pdf

APOPKA POLICE DEPARTMENT PROCEDURAL GENERAL ORDERS Effective Date 04-06-20 Subject 8355.00 ❑ New ❑ Rescinds EXPOSURE CONTROL PLAN Reference 29 CFR 1910.1030 – Bloodborne Pathogens FAC 64E PGO 8360.00 “Employee Health and Wellness Center” F.S.S. 384.287 F.S.S. 112.181 F.S.S. Chapter 381 Reevaluation...

APOPKA POLICE DEPARTMENT PROCEDURAL GENERAL ORDERS Effective Date 04-06-20 Subject 8355.00 ❑ New ❑ Rescinds EXPOSURE CONTROL PLAN Reference 29 CFR 1910.1030 – Bloodborne Pathogens FAC 64E PGO 8360.00 “Employee Health and Wellness Center” F.S.S. 384.287 F.S.S. 112.181 F.S.S. Chapter 381 Reevaluation As Necessary Number Application All Employees Amends 05-22-18 Reviewer/Approved by W. Sanchez (AFD) Shah McKinley Related Forms / Bulletins 2008.08-A Exposure Incident Report 2008.08-B Release of Medical Information 2008.08-C Warrant to Conduct Examination 2008.08-D Affidavit for Warrant to Conduct Examination 2008.08-E Physician's Statement 2008.08-F Return Inventory and Receipt PURPOSE: The purpose of this Order is to establish procedures for providing preventive and protective measures from unnecessary exposure by department personnel to infectious diseases. Although no one means of protection can guarantee the safety of an employee, preventive measures can be employed to help reduce chances of contracting such diseases. DISCUSSION: Communicable and infectious diseases pose a major concern to the general public, and especially to law enforcement personnel. The exposure rates of law enforcement officers are increased due to the continued contact with the general public. Members need to familiarize themselves with methods of prevention on the spread of such diseases and their modes of transmission. A lack of precaution on behalf of law enforcement and emergency medical personnel may cause unnecessary exposure to disease. Therefore, it will be the policy of this department to take whatever measures are feasible to protect the health of its employees and to provide employees with up to date safety procedures and communicable disease information that will assist in minimizing potential exposure while increasing understanding of the nature, potential risks, and severity of various types of Exposure Control Plan Page 1 of 17 exposure. The department will provide and ensure availability of proper protective equipment such as disposable medical gloves, face masks, gowns and eye wear to its employees. DEFINITIONS: 1. AIRBORNE PATHOGENS: Pathogenic microorganisms carried by or through the air and transmitted by respiration or breathing infectious droplets. 2. BLOODBORNE PATHOGENS: Pathogenic microorganisms carried by or through the blood and other body fluids and transmitted by the exchange of infected blood or bodily fluids. 3. ENGINEERING CONTROLS: Those controls that isolate or remove the blood borne pathogen hazards from the workplace. 4. EXPOSURE CONTROL OFFICER: The designated member qualified by training and /or experience, to act as the liaison between the Department and any appropriate medical facility, or the Department of Health and Human Services. 5. EXPOSURE CONTROL PLAN: This order, which is a written program developed and implemented by the Apopka Police Department to establish procedures, engineering controls, personal protective equipment, work practices, and other methods capable of protecting members from exposure to blood borne pathogens, and meets the requirements contained in the OSHA Blood Borne Pathogen Standard. 6. EXPOSURE INCIDENT: Contact with a potentially infectious material arising from performance of a member’s duties. 7. INFECTIOUS AGENT: A microscopic organism such as a virus or bacterium usually found in an infected person. 8. UNIVERSAL PRECAUTIONS: An approach to infection control. POLICY /PROCEDURE: I. Responsibility: A. This order serves as the department’s Exposure Control Plan. The department designated exposure control officer is responsible for this Order and its annual review and update. Exposure Control Plan Page 2 of 17 B. The department's exposure control officer will be appointed by the police chief. C. The exposure control officer will be qualified through recognized occupational training. D. Revisions to the Exposure Control Plan will be the responsibility of the exposure control officer. E. In the absence of the appointed member, the EMS coordinator for the Apopka Fire Department will be the department's exposure control officer. II. Exposure Controls: A. Protective Equipment: 1. Personal Protective Equipment (PPE) is issued to each department member and includes the following items: 2. a. Disposable, single use, latex gloves. b. CPR barrier masks. c. Plastic face shields. Protective clothing such as gowns and shoe covers will be worn in extreme occupational exposure incidents and are available in the biohazard supply cabinet located by the sally port. 3. PPE is disposable and may be placed in the biohazard bin for disposal. 4. Replacement PPE may be obtained by sending an email to the department’s quartermaster detailing the needed replacement. B. Universal Precautions: 1. According to the concept of Universal Precautions, ALL human blood and body fluids WILL BE TREATED as if they are known to be infectious for HIV, HBV, and other blood borne pathogens. 2. In a law enforcement setting, universal precautions refer to: a. The consistent use of disposable, single use gloves, protective face shields, CPR mask and other available PPE appropriate to the situation. b. Exposure Control Plan Proper handling of hypodermic needles and other sharps. Page 3 of 17 c. Immediate and thorough hand washing or cleansing with germicidal hand wipes. d. Immediate and thorough cleaning and decontamination of contaminated equipment, clothing and work surfaces with a ten-to-one water to bleach solution. e. Modification of functions such as searches and processing of physical evidence. C. Controlling Exposure: 1. Appropriate Personal Protective Equipment will be utilized at all times, when practical. 2. Extreme caution should be used during searches to prevent accidental skin punctures. 3. Whenever possible, ask suspects if they are in possession of hypodermic needles, syringes or other sharp objects prior to conducting a search. 4. If it is necessary to search manually, always wear protective gloves and proceed slowly and carefully. 5. Avoid touching the telephone, radio, and any other equipment or personal items with contaminated gloves. 6. Subjects with blood or body fluids on their persons should be transported separately from other subjects when possible. The fire department will be summoned when a subject with body fluids present needs to be transported to a hospital for medical treatment. 7. After the completion of a task or search where personal protective equipment or other protective items were used and the protective equipment has become contaminated with blood or other body fluids, the PPE will be removed with caution, placed in a red plastic biohazard bag, and disposed of within the guidelines set forth in this order. D. Limitations of PPE: Exposure Control Plan Page 4 of 17 1. Personal protective equipment (PPE) is designed to provide protection from serious injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other hazards. 2. Careful selection and use of adequate PPE should protect individuals involved in the risks surrounding their jobs. 3. No single combination of protective equipment and clothing is capable of protecting against all hazards. Thus, PPE should be used in conjunction with other protective methods, including exposure control procedures and equipment. E. Risk Employees and Tasks: 1. Risk determination will be based upon job classification and the work duties, responsibilities and procedures of a member’s assignment. Members identified as “At Risk” include the following: 2. a. Sworn Police Officers b. Crime Scene and Evidence Technicians c. Code Enforcement Situations that may create the potential of an occupational exposure to infectious disease, include, but are not limited to the following: a. Providing first aid b. Arrest situations c. Exposure to areas where the presence of body fluids are, or can be expected to be present F. d. Gathering and handling evidence contaminated with body fluid e. Crime scene processing f. Exposures to body fluids present in police vehicles Crime Scene and Evidence: 1. When members encounter body fluids of any type under uncontrolled, emergency circumstances, they should treat all such encounters as potentially hazardous and employ the proper precautions and procedures. Exposure Control Plan Page 5 of 17 2. Under most circumstances, a crime scene technician will collect contaminated evidence at a crime scene. Members will be guided by all procedures set forth for collection of contaminated evidence. 3. III. In or around Crime Scenes, Members will not: a. Eat b. Drink c. Smoke d. Apply cosmetics or lip balm e. Handle contact lenses f. Have any contact from the hand to the mouth, nose or eyes Exposures: A. Infectious Diseases: 1. The transmission of infectious diseases requires the presence of five factors: a. An infectious agent: A microscopic organism such as a virus or bacterium usually found in an infected person. b. Exit of the infectious agent through the blood or other body fluids (blood borne) or respiration (airborne) of the infected person. c. Contact by the member with contaminated blood or other body fluids, or with airborne droplets of the infectious agent. d. Entry into the member’s body through a needle stick; respiration; contact with the member's mouth, nose or eyes; through broken skin; or by other means. e. Susceptibility or the member’s lack of protection from potential infection. 2. Members should consult with their private physicians regarding susceptibility if they are taking prescription medicines. 3. Members who are pregnant will report, any direct contact with blood or other bodily fluids or with infected persons contacted in the line of duty to their physicians, as soon as possible. B. Types of Exposure: Exposure Control Plan Page 6 of 17 1. The highest level of exposure is through a needle stick injury (or any sharp object) where the member is exposed to a blood or body fluid through a puncture in the skin by a contaminated object (this would include a human bite), or a splash of blood and body fluid to the open skin (a wound on a member) or mucous membranes (eye, nose, mouth, etc.). An exposure can also be airborne, if the type of illness is airborne, and the member is exposed to a carrier of the disease. 2. Contact with Hypodermic Needles and Syringes: a. Hypodermic needles and syringes should be considered contaminated. Members should use caution and take universal precautions when handling hypodermic needles and syringes. b. Hypodermic needles and syringes will be collected and disposed of according to PGO 8518.00, “Property and Evidence Packaging and Storage,” if they are considered evidentiary. c. For disposal of hypodermic needles and syringes which are not considered evidentiary, members shall place them into their department issued sharps container. When full, the member shall dispose of the container at Fire Station 1. A new sharps container may then be obtained from the biohazard supply cabinet located by the sally port door. There is also a large sharps container located at the booking desk. Members shall not place sharps containers or individual sharps items of any kind in the biohazard bins. 3. If a member is injured as a result of coming in contact with a hypodermic needle, they will seek immediate medical treatment and will be guided by the following procedures. a. Photograph the injury and hypodermic needle and then seal the hypodermic needle in a puncture resistant, appropriately labeled, evidence cylinder. b. Enter the photograph and needle into property. It will be kept in the event it needs to be tested. Exposure Control Plan Page 7 of 17 4. Members who have had physical contact with body fluids of another person, regardless of the level, will be considered exposed to a communicable disease. Most exposures do not result in infection; however, members shall document all exposures appropriately. C. Immediate Actions: 1. Exposed Member a. First Aid: 1) Wash the skin with soap and water for a period of 15 minutes 2) Splashes to the mucus membrane (nose or mouth) – rinse with water 3) Eyes - irrigate with large amounts of clean water or saline and remove contact lenses. Do not put lenses in until thoroughly cleaned. b. Post Exposure Network Procedures 1) If the member is injured to the point medical care is necessary, the member will follow employee injury procedures according to PGO 8362.00 and/or the directions of the PEN nurse. a) The PEN will function under the supervision of the Medical Director of Centra Care Urgent Care Centers. 2) The City of Apopka is providing access to medical care and follow-up for occupational injuries as part of the employer’s responsibilities. THE EMPLOYEE IS RESPONSIBLE FOR FOLLOWING THE RECOMMENDATIONS OF THE PHYSICIAN, MEETING APPOINTMENTS, AND UNDERSTANDING HIS OR HER OWN MEDICAL CARE. 3) The exposed member or supervisor will make contact with the Exposure Hotline as soon as possible. The hotline is available twenty-four (24) hours a day, seven (7) days a Exposure Control Plan Page 8 of 17 week. The hotline phone numbers are (407)691-5490 or 1888-807-1020. The caller should select option #2. 4) The hotline nurse will gather the exposed member’s demographics, contact information and a description of the exposure. a) The caller should have the source’s information and location at the time of the call. 5) The hotline nurse will then make an assessment and determine the significance of the exposure. If it is determined that the exposure is significant by the Center for Disease Control (CDC) algorithms, the hotline nurse will then transfer the exposed member to the Post Exposure Nurse (PEN) who will: a) Arrange on-site, initial treatment of significant exposures. b) Perform blood draws of the exposed member and the source, to include Source Rapid HIV testing, which provides results within twenty (20) minutes. c) Connect the exposed member to the Medical Director for HIV Post Exposure Prophylaxis (PEP) discussion. d) Dose HIV PEP per the doctor’s order. e) Provide instructions for follow up care and referral, if needed. 6) If it is determined that the exposure is not significant by assessment with CDC algorithms, the exposed may return to work and seek follow up care as advised by the city physician. 2. Source Actions: a. Exposure Control Plan Obtaining A Source Blood Draw: Page 9 of 17 1) If the exposure meets CDC guidelines as a “significant exposure,” (i.e. the PEN Nurse advises the exposure is significant and recommends the blood from the source), the source can consent to a blood draw or can be compelled through a warrant. 2) Florida Statute 384.287 states that a member, acting within the scope of their employment, who comes into contact with a person in such a way that a significant exposure has occurred may seek a court order directing that the person who is the source of the significant exposure to submit to screening. The department may seek the court order on the member’s behalf. 3) A sworn statement by a licensed physician that a significant exposure has occurred and that, in the physician's medical judgment, the screening is medically necessary to determine the course of treatment for the exposed employee constitutes probable cause for the issuance of the order by the court. 4) The department will be responsible for sending the appropriate court motions to the State Attorney’s Office or the court to have the offending subject tested or his test results released. If a court appearance is necessary, the exposed member may be required to attend the court proceedings requesting the subject’s blood withdrawal for testing. b. Source Consent: 1) The PEN Nurse, watch commander, exposure control officer, city physician, or other designee, can attempt to get the source patient to complete a “Release of Medical Information” affidavit. Copies of all paperwork shall be secured and forwarded to the city’s Human Resources Department. Exposure Control Plan Page 10 of 17 2) All attempts to gain consent from the source will be exhausted before the department moves to obtain a warrant, including letting the source know the department will utilize every legal means in order to obtain blood from the source. 3) If the source is in the hospital, the blood may be obtained from the hospital. If the source is not in the hospital, the source may be transported, after consultation with the PEN Nurse, to the appropriate medical facility for a blood draw. c. Source Refusal: 1) If the source will not consent, the on-call Apopka Police detective may be summoned to assist in the preparation of a warrant, pursuant to FSS Chapter 381. 2) The appropriate forms shall be completed in their entirety and, if the warrant is signed, it shall be executed forthright. The Return, Inventory, and Receipt shall be completed upon receipt of the blood under the requirements of the warrant and returned to the court. Copies of all paperwork shall be secured and forwarded to the exposure control officer. 3) Any and all actions taken will ensure the safety and security of the source with reasonable use of force, the privacy and security of the information obtained, and within the direction of Chapter 381. 4) Any transport of the source may be facilitated by the EMS Coordinator or shift commander. This may require transport by ambulance, standby during the treatment, and return of the source to home or another place. 3. Employee Consent: a. THE EXPOSED EMPLOYEE MUST CONSENT TO AND HAVE HIS OR HER BLOOD DRAWN FOR TESTING. BY Exposure Control Plan Page 11 of 17 LAW, THE SOURCE CANNOT BE TESTED IF THE MEMBER REFUSES TO CONSENT TO A BLOOD DRAW AND TEST. IV. Decontamination and Storage: A. Vehicles: 1. For minor body fluid contamination (i.e., spill), approved cleaning items are located in the cabinet next to the sally port door. Consult with the patrol supervisor and fire department personnel, if necessary. The cleaning materials may be used to remove minor blood, urine, feces, vomit, or any other body fluid contamination. (Fire department personnel are not obligated to clean police vehicles, but may provide technical assistance.) 2. For large fluid contamination, the watch commander will determine whether the member will clean the spill or a contractor is called to clean the spill. If the decision is to call a contractor, the member shall: a. Take the vehicle to fleet operations. (The decision to drive the vehicle or have it towed will be dependent on the size and nature of the spill.) b. The quartermaster will be notified to coordinate with a contracted cleaning agency. B. Property (including uniforms): 1. Disposable department equipment or personal property (contaminated in the line of duty): a. Will be double sealed in a red biohazard plastic bag and disposed of in the red biohazard bins located within the sally port of the police department or at any of the city fire station locations. 2. Non-disposable equipment or personal property: a. Will be double sealed in a red biohazard bag and left in the sally port. The bag shall be clearly marked BIOHAZARD. Uniforms and other clothing may be decontaminated. Exposure Control Plan Page 12 of 17 b. Notice shall be made to the exposure control officer of any clothing that’s needs to be decontaminated. 3. Members will not dispose of or store contaminated equipment or personal property in any manner other than outlined in this Order. 4. Members will notify their immediate supervisor of any contaminated equipment as soon as practical. 5. The Exposure Control Officer will be notified of the infected items and will make arrangements, in conjunction with the quartermaster, to either clean or replace the item. C. Regulated Waste Management: 1. The collection and disposal of infectious waste will comply with established Federal, State and Local Laws, as well as OSHA standards. 2. Discarded infectious waste found or reported by members will be inspected for markings which might identify an owner or user. All items, whether identifiable or not, will be placed in a red plastic biohazard bag. 3. Members will utilize applicable protective equipment in the collection of the waste. 4. Found Regulated Waste: a. City rights of way or property: 1) Small amounts of waste (syringe, biohazard box) will be collected and disposed of properly. The fire department may be called for assistance. Proper disposal is over-bagging soft waste and hard-bagging sharps. The waste will be placed into the fire department's biohazard box for proper disposal. 2) Large amounts of waste that cannot be easily or safely collected may need to be removed by a licensed contractor. The member shall consult with the watch commander for proper notifications. b. Exposure Control Plan Private property: Page 13 of 17 1) Waste on private property is the responsibility of the property owner. 2) The owner shall be notified to remove the waste safely. 3) Code enforcement can be solicited to open a code case. 5. Documenting Found or Reported Regulated Waste: a. The member shall investigate the waste in accordance with applicable state law. b. An incident report shall be completed. c. The assistance of the investigations section or code enforcement may be solicited. d. Assistance from public services may be obtained regarding contractors for the removal and disposal of regulated waste. V. Occupational Exposure Training Program: A. Training for all “At Risk” members will be facilitated through the training supervisor. B. Refresher training on this order will occur annually. C. The exposure control officer will conduct an annual review of the exposure control plan and the procedures outlined herein. D. Newly appointed members will receive training during the orientation phase of training. E. The exposure control officer, or designee, will be responsible for providing this training which will include the following: 1. The familiarization with this Order. 2. Familiarization of Personal Protective Equipment available. 3. Familiarization with the basic epidemiology and symptoms of blood-borne diseases. 4. Familiarization with modes of transmission of blood-borne diseases. 5. Exposure control procedures. 6. Recognition of the international biohazard waste labels and symbols communicating hazards to employees. Exposure Control Plan Page 14 of 17 7. Familiarization with biohazard waste disposal procedures. 8. Explanation of work methods which will prevent or reduce exposure. 9. Explanation of what procedures to follow if an exposure occurs, including post exposure follow-up. 10. F. Question and answer period. Training records will be maintained by the training supervisor and shall include the following: 1. Lesson Plan. 2. Names and qualifications of persons conducting the training. 3. Sign-in sheets with the names and job titles of all persons attending the training session. VI. Hepatitis B (HBV) Vaccination Program: A. Hepatitis B Vaccinations will be offered and available to all “At-Risk” members on a voluntary basis and at no cost to the member. 1. The Employee Health and Wellness Center (My Health Onsite, 176 E 5th St, Apopka, Fl 32703) will facilitate the Hepatitis B Vaccination program. 2. The department will make available a three shot inoculation series of Hepatitis B Vaccinations (or series recommended by the city physician). 3. A designated medical provider from the city clinic will administer the inoculations. 4. The initial offer is extended at the employee’s pre-employment examination and at no point later than 10 days after initial employment. 5. The member will consult with the city physician regarding the program in order to make an informed decision. The member will accept or decline after consultation with the city physician. B. All “At-Risk” members are required to complete the Hepatitis B Vaccination Form indicating their choice to participate in the program. Members who participate are required to complete the entire protocol as prescribed. C. Members may elect not to participate; however, they will be required to sign an acknowledgement of declination. Note: Members electing not to participate may Exposure Control Plan Page 15 of 17 waive their right to a presumption that the disability was suffered in the line of duty. A member may present a written physician’s statement stating immunization would pose a significant risk to the member's health. Absent a written physician’s statement, a member who refuses to be vaccinated may be disqualified from the benefits of the presumption (F.S. 112.181). D. Members who voluntarily refuse to participate in the vaccination program may at any time choose to participate by notifying the police chief's office which will arrange for the member to begin the vaccination program. E. The vaccination form and all documentation of Hepatitis B inoculations will be maintained in the member's medical file in human resources. VII. Records and Reporting: A. Notification of Occupational Exposures. 1. As soon as practical after an exposure, the affected member shall notify their supervisor of the exposure. 2. The supervisor will notify the chief and deputy chief of the exposure as soon as practical. (This may be done through text or direct e-mail.) 3. The member will be guided by the procedures set forth in PGO 8362.00, “Loss, Damage to City Property, or Injury to City Employee,” after any suspected exposure. B. Documentation: 1. All paperwork surrounding an exposure will be sent to the city's Human Resources Department so that an appointment can be made with the city physician. 2. Medical records will be maintained by the Human Resources Department in accordance with the record retention schedule established by the State of Florida. 3. Medical Record Keeping a. Medical records for each employee with occupational exposure will be kept by the Director of Human Resources in a separate, confidential file. Exposure Control Plan Page 16 of 17 b. Records will be made available to employees, their representatives, with written consent and/or as required by law. c. Records will be kept on file for a duration in accordance with Federal and State Law. C. Confidentiality 1. Confidentiality of the exposure, all information received, and of the persons tested must be maintained. Exposure Information is exempt from the Public Records Act. 2. Any employee found to breach confidential medical information to anyone other than those within a direct need to know (Human Resources, Senior Staff) may be disciplined up to and including termination. This includes information regarding the source patient. 3. The City of Apopka’s Human Resources Department will be responsible for the review and tracking of exposure incidents. An Exposure Incident file will be maintained by the city’s Human Resources Department and housed within that office. By Order of: Michael McKinley, Police Chief Exposure Control Plan Page 17 of 17