I. Introduction Loss Prevention Surveys

Handwashing

Employees should wash their hands immediately after removal of gloves or PPE. They

should wash areas which came in contact with blood or other potentially infectious

material immediately with soap and water.

Disposal of contaminated sheets, linens and bedding

Employees should not touch or handle contaminated sharps. Small items like hypodermic

needles and syringes should be picked up with tongs and placed in a “sharps container”.

Sharps should never be placed in trash containers or any other container that isn't

puncture resistant.

Soiled linens and bedding should not be sorted in the guest rooms. Linens and bedding

should be handled with protective gloves and placed in BIOHAZARD bags. If they are

to be washed at the hotel, only trained employees should handle the contaminated

laundry. These employees should be provided with gloves, aprons, and masks as needed.

The red bag should not be re-used. It should be disposed of as hazardous waste. Linens

and bedding should be washed with a disinfectant. Material that can not be cleaned

should be disposed of as hazardous waste.

Cleaning and decontamination

Bleach and water will decontaminate most of the equipment found in the hotels. This is

the preferred method for decontamination because it doesn't expose the employee to

harsh chemicals and they are readily available. It is important to be sure that all of the

hazard is removed and there are no residues left on the equipment. PPE should always be

used while cleaning and decontaminating equipment.

Hepatitis B Vaccinations

This section was originally written by OSHA to apply to the Health Care industry and

those professionals exposed due to their health care occupation. However, if it has been

determined that employees have been exposed to Hepatitis B, you must make available to

the employee the Hepatitis B vaccination series. There must also be a post-exposure

follow-ups for all employees who have had an exposure incident. You must make sure

that the medical evaluations and procedures including the Hepatitis B vaccination series

and post-exposure evaluation are: Made available to the employee at no cost; Made

available to the employee at a reasonable time and place; Performed by or under the

supervision of a licensed physician or by or under the supervision of another licensed

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healthcare professional. If the employee declines to receive the vaccination after an

exposure incident, that employee should sign the declination form provided in the

appendix. If the employee decides at a later date to then receive the Hepatitis B

vaccination, you must make it available at that time. If there is an exposure incident, the

Hepatitis B vaccination should be given immediately. It should be your goal never to be

in a situation where you must give the Hepatitis B vaccination due to an exposure

incident. Through proper engineering controls, training, education, and the use of PPEs,

exposure incidents can be avoided.

All first aid providers who render assistance in any situation involving the presence of

blood or other potentially infectious materials, regardless of whether a specific exposure

incident occurs, should be offered the full Hepatitis B immunization series no later than

24 hours following the incident. In order for this to apply, there must be first aid

procedures in place. These procedures include:

Incident reports must be filed with names of first aid providers.

These reports must be accessible to employees and OSHA.

First aid providers must be trained in the provisions of Bloodborne Pathogens

Standards.

Post Exposure Procedures

If an exposure incident occurs as mentioned above, the hotel should offer the Hepatitis B

vaccine as well as a post exposure evaluation and follow up. Any medical care required

or received by the employee due to the exposure incident must be provided at no cost to

the employee.

The hotel must offer and allow the employee to receive the treatment at a convenient time

and place for the employee. Typically this means it will be offered during normal

working hours. If there are travel expenses associated with the treatment, the hotel must

bear the cost for this as well.

The following procedures must also be followed after an exposure incident:

An investigation and incident report must be completed that substantiates all of the

facts surrounding the cause of the incident and what corrective action will be taken to

prevent it from happening again. Be sure to indicate whether or not the employee was

wearing PPEs at the time of the exposure incident. The use of PPEs must be stressed

heavily during training. If it is determined that the employee was not wearing PPE,

you must indicate why it was not used, what is the likelihood of this happening again,

and what can be done to make sure the employee uses PPEs in the future.

Identify the source of the incident. If a housekeeper is stuck by a syringe left in the

guest room we should identify the guest (or the last person who had the room in cases

of checkout) and discuss the incident with them. If you are not able to identify the

person responsible, then you should state what steps you took in your attempts to

identify this person.

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If the source person is identified, you should ask them for consent to perform a blood

test. If they refuse, this should be documented in your incident report.

If blood testing is done on the source individual, the results should be made available

to the exposed employee. However, the employer is not authorized under law to be

informed of the results of the blood test. The licensed healthcare professional is only

required to give this information to the employee.

Employees involved in an exposure incident have at least 90 days following the initial

blood collection following the incident to decide to test for HIV. The collected blood

should be preserved for at least 90 days following its collection if the employee is not

immediately tested for HIV following the incident.

The employer should obtain a written opinion (report) from the health care

professional within 15 days of the incident on the status of the Hepatitis B vaccination

and whether the vaccination was completed. The health care professional should

indicate that a post exposure evaluation was performed on the exposed employee and

the employee was informed of the results along with any medical conditions resulting

from the exposure. This report should also state if there is further evaluation or

treatment required. It is not necessary to state what treatment or evaluation is needed,

only that more is required.

Recordkeeping Procedures

An employee training sign off form is included in the appendix and as training is

completed, each employee should sign the form documenting this training. These should

be kept in a manner that is readily available for review. It is suggested these be kept in

the employee's personnel file, in each department, and a master list kept of all employees

who have received this training. This will ensure records can be obtained when needed.

All employees should receive retraining within one year of their initial training and

each year thereafter . Training records must be maintained for three years. The medical

records of employees must be kept for the duration of their employment plus 30 years.

OSHA’s Needlestick Safety and Prevention Act – With the enacting of the Needlestick

Safety and Prevention Act on April 18, 2001, OSHA has now established new

recordkeeping requirements for needlestick injuries. The recordkeeping requirements

state that:

“The employer shall establish and maintain a sharps injury log for the recording of

percutaneous injuries from contaminated sharps. The information in the sharps injury log

shall be recorded and maintained in such manner as to protect the confidentiality of the

injured employee. The sharps injury log shall contain, at a minimum: (A) The type and

brand of device involved in the incident, (B) the department or work area where the

exposure incident occurred, and (C) an explanation of how the incident occurred.”

In addition, the log should contain enough information to allow for the identification of

the device, location, and circumstances surrounding an exposure incident, without

compromising the privacy of the individual.

From a practical stance, each hotel should maintain a log of all needlestick injuries. The

log should identify each person with a separate, unrecognizable ID. This ID should

correspond to the employee’s file for this incident, which will contain all personal

information. The log should also identify the type of device (i.e. hypodermic needle,

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etc.), the brand of device (if known), the location of the incident (i.e. guestroom, laundry

room, etc.), and a brief description of the accident (i.e. employee reached into garbage

can and was pricked by needle, etc.).

The new OSHA worker’s injury forms (OSHA forms 300, 300A and 301) can be

effectively used as the required log, as long as the brand name of the needlestick device is

recorded on the form. In fact, all needlestick injuries should be included on the new

forms, so it may be advantageous for the hotel to use those forms, rather than create a

separate needlestick log.

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SAMPLE

Bloodborne Pathogens

Written Exposure Control Plan

Purpose: This section contains the hotel's written procedures for developing a program

to reduce health risks due to exposures from blood and other infectious materials. The

program includes the following information:

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  Determination of exposures to employees.
  
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  How the employees will be informed of the hazards.
  
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  What will be done to reduce the hazards and exposures.
  
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  Vaccination policy.
  
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  Recordkeeping procedures.
  
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  Annual review and updates.
  

EMPLOYEE EXPOSURES:

Due to the nature of most jobs in a hotel there is a potential for exposure to blood and

other infectious material. There should be an ongoing evaluation of each job function to

identify tasks and work methods that could result in exposures to Bloodborne pathogens.

The hotel should use the Univer sal Precaution approach to reduce the risks associated

with Bloodborne pathogens. The evaluations should include:

1. An incident report completed for all exposure incidents. The supervisor or department

head should be notified whenever an exposure incident has occurred. This individual

will then need to complete an investigation. The investigation and subsequent report

should be completed on the same day of the incident. Immediate corrective action and

decontamination procedures will be implemented if it is determined that the exposure

is still present and poses a hazard to other employees.

2. Copies of the incident and the investigation report will be sent to the safety committee

for review. They will examine the exposures and determine if other corrective action

is needed. If necessary, a special safety committee meeting will be called to review

the incident. The main purpose of the committee review is to ensure that additional

corrective action isn't being overlooked and to help develop training programs when

more training is needed. However, in no case should corrective action be delayed for

a committee review when other employees are exposed to a hazard.

3. If additional corrective action or training programs are needed, the safety committee

should develop an action plan that describes what will be done. If you have trouble

with this you may contact the Loss Prevention Department for assistance. The action

plan should include personnel responsibilities and time frames for each action that is

to be completed. Before issuing the plan, the Safety Committee Chairperson will need

to take it to the General Manager for approval. The Safety Committee Chairperson

will have the responsibility to see that the action plan is completed and implemented

correctly. The results and status will be discussed in each meeting until all actions are

completed.

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4. If an incident occurs because of a failure to provide or use the proper PPE, the reason

for the failure will need to be determined. If additional PPE is required, it should be

provided as quickly as the item can be purchased and delivered.

5. All employees should receive training on proper procedures for handling and disposal

of needles and linens which have possibly been exposed to blood or other infectious

material. Special attention will be given to the training of housekeepers and laundry

employees since they typically are most affected. If there is an incident involving a

hypodermic needle or syringe, the person who last stayed in the room will need to be

contacted as soon as possible. You will need to obtain that person’s consent to

perform a blood test if it is determined to be theirs.

6. Each job and job function will be reviewed in an effort to identify potential hazards.

The Safety Committee will be responsible to develop procedures that ensure all jobs

are reviewed. The person performing the job will have the opportunity to provide

input on hazards through their Safety Committee representative. As potential hazards

are identified, the Exposure Determination Sheet should be completed. When all job

hazards or potential hazards have been identified, they will be reviewed by the Safety

Committee to see if any of these hazards can be eliminated through engineering

controls. When engineering controls are not possible, the Safety Committee will

review the job procedures to ensure PPEs are provided and there is training for this

particular type of exposure.

7. Copies of the Exposure Determination Sheet will be given to each department head

after all jobs have been reviewed. It will be the responsibility of the department heads

and supervisors to become familiar with the exposures listed. They are also

responsible for making sure all employees follow the safe practices that have been

established for their job function. They will also need to go over the exposures and

procedures with any part time or transferred employees.

8. Contaminated surfaces should be decontaminated with the appropriate disinfectant

following the rules established by the hotel. This will be done only by employees

trained in these procedures. Attached with this plan is a list of approved disinfectants.

You should also include a list of employees trained in decontamination procedures.

EMPLOYEE INFORMATION:

The hotel's employees should be made aware of any control plans implemented by the

Safety Committee that affect their job functions. The Safety Committee is charged with

the review and implementation and should be able to discuss the procedures in this

program at any time with any of the employees. The employees, the department

manager, and the supervisors will develop training programs for each employee in their

department describing the hazards and hotel policy regarding this written plan.

Employees will be able to review this program at any time and should be encouraged to

make suggestions for improvements. All suggestions will be reviewed by the full Safety

Committee to determine if they will be used. The employee will be informed of the

results of the Safety Committee review any time they make suggestions.

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HAZARD REDUCTION:

The hotel’s Safety Committee should make special efforts to identify hazards and take

corrective action before employees become exposed or possibly injured. The first step

will include engineering controls to eliminate the hazard whenever possible. When

engineering controls are not possible, training and PPEs will be utilized. The following

are some of the basic procedures that should be implemented:

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  Employees will be trained in identifying “sharps” and what to do when there is
  
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  contact with them. The word "sharps" will be used to describe anything that can cause
  
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  a puncture wound or cut and expose employees to blood or other infectious materials.
  
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  Employees that find a “sharp” should not attempt to dispose of it themselves unless
  
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  they have been properly trained in the established procedures. The employee should
  
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  immediately contact their supervisor to dispose of the sharp for them.
  
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  Employees will be instructed not to reach into waste baskets or areas where
  
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  contaminated sharps could be found.
  
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  Employees who could have contact with bedding and linens will be instructed to
  
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  check it for either sharps, blood or body fluids before handling. PPEs in the form of
  
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  gloves, face and eye protection will be given to employees to wear if there is a
  
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  possibility they could be exposed to contaminates.
  
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  If employee trash bins or carts are full and need to be compacted, they should use a
  
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  different trash can to push down the trash. The employee should not use their hands
  
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  to push or compact trash in a trash container.
  
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  PPE, trash bins, waste containers, tools or equipment should be decontaminated
  
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  before use if they have become contaminated.
  
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  Employees will immediately wash their hands whenever there is contact with blood
  
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  or contaminated equipment.
  
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  Hands will be washed following the removal of PPEs. All PPEs will be cleaned and
  
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  maintained according to the manufacturer’s instructions. PPEs will be supplied and
  
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  maintained at no cost to employees.
  
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  Employees should immediately inform their supervisor of any defective PPE so it can
  
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  be replaced. This includes any PPE that is cracked, peeling, torn, punctured or
  
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  otherwise damaged. If equipment should become contaminated, labels will be
  
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  attached to inform other employees or service people of the hazard. The label will
  
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  state BIOHAZARD and be in fluorescent orange or orange-red. Bedding or items
  
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  that can be placed in containers will not have labels but will be placed in red bags or
  
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  red containers.
  
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  The employees need to sign the attached Bloodborne Pathogens Training Sheet indicating
  
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  they are aware of this program and have been trained in the procedures.
  

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ANNUAL REVIEW AND UPDATES:

This entire program will be reviewed at least once a year (more often if exposures change

or more exposures are identified) by the Safety Committee. All employees MUST be

informed of any changes by posting notices on the employee bulletin board or in a staff

meeting (it is a good idea to do both). The information given to the employees must

include the names of who to contact in order to review the program. New employees

should receive training on these procedures prior to starting work as part of their new

employee orientation.

ANNUAL RETRAINING:

All employees should receive retraining within one year of their initial training and each

year thereafter.

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Bloodborne Pathogens

Exposure Determination by Jobs

The following is a sample list of jobs that could have exposures to Bloodborne

pathogens. This list IS NOT a list of jobs where the employees have been exposed. It is

only a list of jobs where circumstances could develop and there may be an exposure.

This list IS NOT all inclusive. Each hotel must evaluate their particular jobs to determine

if an exposure exists. As jobs are identified that are believed to have exposures, these

jobs should be listed on the exposure determination sheet included with this program.

HOUSEKEEPING

Bedding: Blankets, sheets, and pillow cases should be handled only as instructed by

supervisors. They should be inspected for blood, body fluids, needles, or other sharps that

could cause a puncture wound or cuts.

Carpet, Couches, chairs, and furniture: The employees must watch for needles or

sharps left in or on any of these items. DO NOT reach hands between cushions or stick

hands in drawers without looking in them first. Also look for blood or other body fluids.

Trash Containers: Never reach into trash containers. Empty them by lifting and

dumping the entire waste basket or container or as instructed by supervisors.

Needles: If a needle or syringe is found DO NOT attempt to pick up or handle it. Call

your supervisor immediately who will dispose of it according to hotel policy.

Bathrooms: Pick up towels by edges and inspect them before handling. Watch for razor

blades, needles or other sharps. Never reach into a pile of towels.

LAUNDRY:

The major exposure in this area is blood or body fluids found on linens. Dirty linens

should be inspected and handled according to instructions given by your supervisor.

FOOD SERVICES:

Exposures in this area are not as common as those previously listed but there may be

some exposures due to guests who may bleed on table cloths, napkins, or fixtures. There

may also be exposures from being cut while cleaning up broken glass or from improper

disposal of glass that has blood on it.

KITCHEN:

Exposures in this area could be from trash, broken dishware, blood on silverware, blood

on machinery, knives (causing cuts or punctures), and fixtures.

BUSPERSONS:

Exposures here could range from contaminated dishes or improperly disposed of trash to

sharps found in bus pans.

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ROOM SERVICE:

Possible exposures could be from broken glass and sharps left on room service trays left

for pickup.

BANQUET SETUP:

Exposure in this area is usually from tables, fixtures and table cloths that may have

become contaminated.