Michigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs (LARA)
DOCUMENT IDENTIFIER:
MIOSHA-ADM-15-8
DATE:
December 11, 2015
SUBJECT: MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
I.
Purpose. This instruction is to identify the procedures for ensuring uniform compliance with Part 554. Bloodborne Infectious Diseases by all MIOSHA M-FACT members.
II.
Scope. This instruction applies agency-wide.
III.
References. Occupational Health Standard Part 554. /R325.70001 et seq., Bloodborne
Infectious Diseases.
IV.
Distribution. MIOSHA Staff; OSHA Lansing Area Office; General; S-drive Accessible;
MIOSHA Weekly; and Internet Accessible.
V.
Cancellations. This instruction cancels Agency Memorandum MIOSHA-MEMO-ADM-
09-7, MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan, as amended.
VI.
Expiration. One year from date of issuance.
VII.
History. History of previous versions includes:
MIOSHA-MEMO-ADM-09-7R3, May 28, 2014.
MIOSHA-MEMO-ADM-09-7R2, November 13, 2012.
MIOSHA-MEMO-ADM-09-7R1, August 10, 2010.
MIOSHA-MEMO-ADM-09-7, June 26, 2009.
VIII.
Contact. Shellene Boyd and Sherry Scott , Coordinators of M-FACT.
IX.
Originator: Martha B. Yoder, Director
X.
Original Date of Preparation. June 10, 1993
XI.
Annual Review Dates. May 28, 2014 and December 11, 2015
XII.
Significant Changes.
A.
Incorporated Agency Memorandum MIOSHA-MEMO-ADM-09-7, MIOSHA
First Aid Crisis Team (M-FACT) Written Exposure Control Plan as amended
B.
Eliminated Appendix E and included the approved medical providers’ information in Section XXIV. Post-Exposure Evaluation and Follow-up.

MIOSHA-ADM-15-8
December 11, 2015
MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
XIII.
First Aid Crisis Team.
To the extent possible, the team has two members from each Michigan Occupational
Safety and Health Administration (MIOSHA) division and each field office. The
MIOSHA First Aid Crisis Team (M-FACT) member total will not exceed fifteen.
The M-FACT is established within the MIOSHA to assist in responding to medical emergencies for personnel located in or around MIOSHA facilities. The agency director will appoint the M-FACT.
It is our intent to provide appropriate (cardiopulmonary resuscitation and/or first-aid), immediate assistance during the first few minutes before medical help arrives, by establishing an M-FACT and providing training and protections of a medical emergency for team members.
XIV.
M-FACT First-Aid/CPR/AED Training.
The M-FACT will be provided with first-aid, CPR, and AED training twice per year by an in-house and/or contracted certified instructor.
XV.
Exposure Determination.
In the course of their volunteer duties M-FACT members may have exposure to bloodborne pathogens when they perform CPR/first-aid. The M-FACT will be considered "Category A" as defined in the Michigan Part 554, Bloodborne Infectious
Diseases Standard (R 325.70001 et seq.).
XVI.
Compliance Methods/Standard Operating Procedures.
Universal precautions will be observed by all M-FACT members at all times while providing CPR and/or first-aid in order to prevent contact with blood or other potentially infectious material (OPIM). Other potentially infectious materials include the following:
A.
Semen.
B.
Vaginal secretions.
C.
Amniotic fluid.
D.
Cerebrospinal fluid.
E.
Peritoneal fluid.
F.
Pleural fluid.
G.
Pericardial fluid.
H.
Synovial fluid.
I.
Saliva in dental procedures.
J.
Any body fluid that is visibly contaminated with blood or OPIM.
K.
All body fluids in situations where it is difficult or impossible to differentiate between body fluids.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
All blood and OPIM will be considered infectious regardless of the perceived status of the source individual.
L.
Saliva, sweat, tears, urine, feces, and vomit are not considered OPIM except in cases (J) or (K) above.
XVII.
Engineering Controls and Work Practices.
Engineering controls were not deemed applicable for the anticipated exposure potential of M-FACT members. Exposure potential will be reevaluated annually at a minimum
(see Appendix A ). Work practice controls are limited to hand washing and housekeeping
practices. Employees will be instructed and trained to properly decontaminate blunttipped scissors and other non-disposable items used in an M-FACT emergency using an appropriate Environmental Protection Agency (EPA) List B registered disinfectant
(tuberculocide).
Hand washing facilities are available to the employees who incur exposure to blood or other potentially infectious materials. MIOSHA requires that these facilities be readily accessible. Hand-washing facilities are available within all MIOSHA office settings.
Upon removal of personal protective gloves, employees shall wash hands and any other potentially contaminated skin area immediately or as soon as feasible with soap and water.
If employees incur exposure to their skin or mucous membranes, then those areas shall be washed or flushed with water immediately or as soon as feasible following contact.
XVIII.
Needles and Sharps.
M-FACT members are prohibited from using needles or other sharps. The agency policy is to provide blunt-tipped scissors in each first-aid kit, which may be used to cut a piece of clothing or bandage.
XIX.
Work Area Restrictions.
M-FACT responses are limited to incidents of an emergency nature occurring on the premises of a MIOSHA office.
In accordance with MIOSHA Administration and OHR policy, MIOSHA employees shall not transport another employee to the hospital. The affected employee must be transported by ambulance, a friend, or family member, or ambulance.
XX.
Personal Protective Equipment/Standard Operating Procedures.
All personal protective equipment (PPE) used by M-FACT members will be provided without cost to themselves. PPE will be chosen based on the anticipated exposure to blood or other potentially infectious materials. The protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employees' clothing, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time for which the protective equipment will be used.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
The following PPE is used by M-FACT members:
Gloves First-Aid, CPR
One-way resuscitation shields/masks CPR
Gloves shall be worn during all procedures. One-way resuscitation shields shall be used in all CPR procedures. All members of the M-FACT shall be provided a personal CPR shield and supply of gloves. Each first-aid kit in the agency shall have a CPR shield and supply of gloves. All PPE will be cleaned, laundered, or disposed of by the employer at no cost to employees. Should an M-FACT member's clothing become soiled with another person's blood or OPIM during the course of their M-FACT duties, they shall remove the contaminated clothing as soon as possible. This clothing will be laundered at the agency's expense. The clothing will be identified as contaminated and any individual with potential for exposure will be notified and protected from exposure. Contaminated clothing will be bagged in common waste bags with a biohazard sign attached. All repairs and replacements of an M-FACT member's contaminated personal clothing will be made by the agency at no cost to the employee.
All PPE will be removed prior to leaving the work area. Gloves used by M-FACT members are disposable. CPR resuscitation shields are either fully disposable or have a disposable valve. Resuscitation equipment that is not disposable will be decontaminated
using an appropriate EPA List B registered disinfectant (tuberculocide). See Appendix B
and C for disinfecting and cleaning procedure.
Disposable gloves or any other first-aid materials contaminated with blood or OPIM shall be placed in normal solid waste trash containers. This material is not considered a
"regulated waste" as defined in the Michigan Part 554, Bloodborne Infectious Diseases
Standard, Rule 2(w).
First-aid kits and CPR masks will be located at the following locations which are well labeled:
A.
Mason Building
Technical Services Division (TSD), Radiation Safety Section - 2nd Floor East
Wing, Cabinet marked First-Aid Supplies Column LA-11
TSD, Management Information Safety Section - 2nd Floor East Wing, Cabinet marked First-Aid Supplies Column E3
Consultation Education and Training Division - Drawer marked First-Aid
Supplies Column KA-10
Construction Safety and Health Division - Cabinet marked First-Aid Supplies
Column Q2
General Industry Safety and Health Division - Cabinet marked First-Aid Supplies
Column LA9
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
B.
Field Offices
Grand Rapids On a shelf in bookcase near Men’s restroom
Cadillac Place
Saginaw
Equipment Room
Library/Conference Room
Lab Top Lateral File in Secretary’s Desk
XXI.
Automatic Emergency Defibrillators (AEDS). AEDs are stored in the following locations:
A.
Mason Building
2nd Floor East Wing Cabinet Column LA-11
2nd Floor East Wing Cabinet Column E3
B.
Field Offices
Grand Rapids On a shelf in bookcase near Men’s restroom
Cadillac Place
Saginaw
Equipment room
Outside conference room
Lab Near ICM
XXII.
Housekeeping and Waste Disposal.
A.
Janitorial personnel, not employed by MIOSHA or LARA, will provide housekeeping service in buildings occupied by MIOSHA personnel. In such circumstances, any extensive cleanup of blood or OPIM (items saturated or dried and caking) would be performed by the janitorial service, not by M-FACT members or other MIOSHA personnel. Only M-FACT members located at the
Lab will perform blood and OPIM clean up. Spill response training will be
provided to Lab M-FACT members annually. See Appendix B
and C for
disinfecting and cleaning procedures.
B.
The use of gloves is required to assist with minor injuries (i.e., a bloody nose or a paper cut, etc.), for which no outside emergency medical assistance is required.
Disposal of contaminated gloves, with any accompanying Band-Aid, gauze, toweling, etc. shall be in accordance with the Personal Protective
Equipment/Standard Operating Procedure. Potentially contaminated surfaces will be disinfected using a facility supplied EPA List B registered disinfectant
(tuberculocide).
C.
Major medical incidents, where outside medical assistance is required, will require all used PPE, Band-Aids, gauze, toweling, etc. to be placed into designated red bags or containers, provided by the emergency medical service provider. The emergency medical service provider will then remove the red bags or containers from the building.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
XXIII.
Hepatitis B Vaccine (HBV).
A.
All M-FACT members who have been identified as having exposure to blood or other potentially infectious materials will be offered the hepatitis B vaccine at no cost. The vaccine will be offered within ten working days of their initial assignment to work involving the potential for occupational exposure to blood or other potentially infectious materials unless the employee has previously had the vaccine.
B.
Employees who desire HBV antibody testing before deciding whether or not to receive the HBV vaccination will receive the test at no cost to themselves.
C.
Employees who decline the hepatitis B vaccine will sign a declination statement.
These statements will be kept as an employee medical record with the agency's administrative personnel records.
D.
Employees who initially decline the vaccine but who later wish to have it may then have the vaccine provided at no cost. The agency's M-FACT coordinator(s) are responsible for assuring that the vaccine is offered, administered, or that the waivers are signed. The Ingham County Health Department and/or Sparrow
Occupational Health Service will administer the vaccine and titre.
XXIV.
Post-Exposure Evaluation and Follow-up.
A.
An exposure incident is defined as an incident where the eye(s), mouth, other mucous membrane, non-intact skin, or punctured into the skin, comes in contact with blood or OPIM. The following actions must be done if an exposure incident occurs during the course of rendering first aid:
1.
Report the incident to an M-FACT coordinator(s).
2.
Fill out an incident report. See Appendix D .
3.
Proceed to the identified healthcare facility for evaluation and treatment in accordance with the Michigan Part 554, Bloodborne Infectious Diseases
Standard.
B.
Please see a list of Occupational Medicine Clinics provided by the Michigan Civil
Service Commission's Disability Management Office at the Clinic List for
Workers Compensation link under the resources tab.
C.
The post-exposure follow-up will include the following:
1.
Documentation of the route of exposure and the circumstances related to the incident.
2.
If possible, the identification of the source individual and the infectivity status of the source individual. The blood of the source individual will be tested (after consent is obtained) for HIV/HBV infectivity.
3.
Results of testing of the source individual will be made available to the exposed employee. The exposed employee will be informed about the
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan applicable laws and regulations concerning disclosure of the identity and infectivity of the source individual.
4.
The employee will be offered the option of having their blood collected for testing of their HIV/HBV serological status. The blood sample will be preserved for at least 90 days to allow the employee to decide if the blood should be tested for HIV serological status. However, if the employee decides prior to that time that testing will be conducted, then the appropriate action can be taken and the blood sample discarded.
5.
The employee will be offered post-exposure prophylaxis in accordance with the current recommendations of the U.S. Public Health Service.
6.
The employee will be given appropriate counseling concerning precautions to take during the period after the exposure incident. The employee will also be given information on what potential illnesses to be alert for and to report any related experiences to appropriate personnel.
D.
Following an exposure incident, a written opinion shall be obtained from the health care professional who evaluates M-FACT members within 15 working days of the completion of the evaluation. A copy of the required written opinion will be supplied to the employee.
Health care professionals shall be instructed to limit their opinions to:
1.
Whether the Hepatitis B vaccine is indicated and if the employee has received the vaccine, or for evaluation following an incident.
2.
That the employee has been informed of the results of any and all evaluations, including HIV, and;
3.
That the employee has been told about any medical conditions resulting from exposure to blood or OPIM. (Note that the written opinion to the employer is not to reference any personal medical information.)
XXV.
Training.
A.
Initial training for all M-FACT members will be conducted prior to assignment of tasks where occupational exposure may occur and annually thereafter.
B.
Training for employees shall include an explanation of the following:
1.
The MIOSHA Part 554, Bloodborne Infectious Disease Standard.
2.
The epidemiology and symptoms of bloodborne infectious diseases.
3.
Modes of transmission of bloodborne infectious diseases.
4.
This Exposure Control Plan, i.e., points of the plan, lines of responsibility, how the plan will be implemented, etc.
5.
Procedures which might cause exposure to blood or OPIM at this facility.
6.
Control methods which shall be used to control exposure to blood or
OPIM.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
7.
PPE that is available and who should be contacted concerning the equipment.
8.
Post-exposure evaluation and follow-up.
9.
Signs and labels used to identify biohazard waste.
10.
HBV program.
11.
Additional items described in Rule 16, of MIOSHA's Part 554,
Bloodborne Infectious Diseases Standard.
C.
The M-FACT coordinator(s) will prompt members to conduct a quarterly First-
Aid Kit inspection when they are notified of training. Inspection records are to be maintained with the location's Exposure Control Plan. Training for M-FACT members shall involve lectures, videos, and hands-on sessions.
XXVI.
Recordkeeping.
The agency shall establish and maintain an incident record for each employee with occupational exposure and keep it for the duration of employment plus 30 years. Records
shall be kept confidential. The incident report (see Appendix D ) shall include at a
minimum all of the following:
A.
Name
B.
HBV status
C.
Copies of any past exposure/evaluation or follow-up
Training Records:
D.
Date(s)
E.
Summary of Contents
F.
Names and qualifications of trainers
G.
Names and job titles of all trainees
H.
Maintain record for three (3) years
The M-FACT member shall keep hepatitis vaccination records until all three shots in the series are completed. A copy of the completed vaccination record will be placed in the
MIOSHA files.
Agency administration shall keep records for the M-FACT.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
The following protective work clothing and/or equipment is being considered and/or implemented:
The following work practice controls are being used to reduce exposure:
UNIVERSAL CONTROLS/PRECAUTIONS
.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
Equipment: Decontamination and Cleaning
PROCEDURE: In the event that non-disposable equipment (blunt-tipped scissors, resuscitation mask) becomes contaminated with blood or OPIM, the following procedure will be performed by MIOSHA First Aid Crisis Team (M-FACT) members.
1.
Don nitrile examination gloves before touching contaminated non-disposable equipment.
Place equipment into any available, plastic lined refuse container. Transport to nearest available janitorial/utility closet equipped with a sink and disinfecting supplies.
2.
If a refuse container is not available, place the non-disposable equipment onto a bundle of office papers sufficient to prevent leakage. Wrap paper around non-disposable equipment and transport to nearest available janitorial/utility closet equipped with a sink and disinfecting supplies.
3.
In a location (i.e., janitorial/utility closet or restroom) equipped with a sink and disinfecting supplies- a) Doff examination gloves, place into available waste container. Wash hands with soap and water. b) Don new pair of examination gloves, activate water supply. c) Adjust temperature of water to a tepid state. Ensure that the water pressure doesn’t create a splash hazard. d) Remove and place non-disposable equipment into sink. Discard plastic waste container liner or office papers used to transport equipment in waste container. e) Remove any gross contamination from non-disposable equipment. f) Disinfect non-disposable equipment with a facility provided EPA List B
(tuberculocidal) agent. Follow instruction on disinfectant container. g) If an EPA List B (tuberculocidal) agent is not available, mix a fresh solution of sodium hypochlorite (bleach) to a ratio of 1:10 – 1:100. Clean all surface areas of equipment, allow a minimum of 10 minutes to elapse before rinsing equipment.
Allow to air dry.
4.
Remove gloves and discard into available waste container, wash hands.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
Non-Porous Surface Areas: Decontamination and Cleaning
PROCEDURE : In the event that non-porous work surfaces (desks, vinyl floors, etc.) becomes contaminated with blood or OPIM during a minor medical incident (bloody nose, paper cut), the following procedure will be performed by MIOSHA
Emergency Response Team (M-FACT) members.
It is the agency’s policy that all extensive clean-up of blood or OPIM will be performed by the facility’s janitorial staff, not by M-FACT members. ONLY lab M-FACT members will engage in minor spill response and therefore, must adhere to the following spill response procedures.
1. Determine if the blood or OPIM spill falls under the M-FACT scope of response. If the spill is of a minor nature (not saturated or dried and caking), continue to step 3.
2. If the spill is determined to be major, M-FACT members shall not proceed with clean-up and will contact appropriate facility management personnel for cleanup.
3. Prevent access to spill area by unauthorized personnel/visitors.
4. Secure materials necessary to clean minor spill: a) Plastic bags. b) Paper towels. c) Vinyl or nitrile examination gloves. d) Disinfecting solution.
5. Don latex or nitrile examination gloves before touching contaminated non-porous work surfaces.
6. Remove gross contamination from non-porous work surface with paper towels. Discard contaminated paper towels into plastic bag.
7. Disinfect non-porous work surface with a facility provided EPA List B (tuberculocidal) agent.
Follow instructions on disinfectant container.
8. If an EPA List B (tuberculocidal) agent is not available, mix a fresh solution of sodium hypochlorite (bleach) to a ratio of 1:10 – 1:100. Clean all surface areas impacted by the blood or OPIM, allow a minimum of 10 minutes to elapse before rinsing surface. Allow to air dry.
9. Remove gloves and discard into plastic bag. Place plastic bag into available waste container, wash hands.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
Michigan Department of Licensing and Regulatory Affairs
MIOSHA
INCIDENT REPORT
DATE:
SEND TO: Coordinator(s) of the MIOSHA First Aid Crisis Team (M-FACT)
FROM:
SUBJECT: First Aid or CPR Response
Victim Name
Date of Incident:
Member or Members of Team Involved:
Location of Incident:
Time:________________
Description of Incident:
Was first aid given? YES
If yes, what type of aid was provided?
NO
Was outside medical assistance required? YES NO
If yes, did you have any problems notifying medical assistance or have any other problems? Please explain.
Please indicate any additional training or changes in our procedures that will help in any future incidents.
Signature of Person Reporting:
NOTE: If team member or members were exposed in an incident, complete evaluation of exposure report.
Exposure is defined as contact to eyes, mouth, nose, non-intact skin, or a puncture through the skin, to blood or OPIM.
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MIOSHA-ADM-15-8
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MIOSHA First Aid Crisis Team (M-FACT) Written Exposure Control Plan
EVALUATION OF EXPOSURE INCIDENTS
1.
2.
Brief description/circumstances of exposure incident and date:
Type and brand of device involved in incident exposure:
1.
4.
Source individual information, if available:
Could the exposure incident have been prevented with proper use of work practice controls? (If no, go to question five).
Yes No__________
5. Is the work practice control in question addressed in the employer’s exposure control plan?
Yes No
6.
7.
If yes, what is the rationale for non-compliance with the work practice control in question?
Would the utilization of work practice controls have:
Prevented the delivery of health care or public safety services?
Posed an increased hazard to the safety of the worker or co-worker?
Prevented or decreased the risk for occupational exposure?
8. What changes can be instituted to prevent such occurrences in the future?
9. Was the team member(s) sent to a physician because of exposure? If yes, attach a physician ’ s report.
Date:
13