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.
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