I. Introduction Loss Prevention Surveys

BARTENDERS:

Knife cuts and broken glass account for most of the exposures here.

SECURITY:

Contact with contaminated equipment, fights or altercations where blood is present, and

applying first aid represent the greatest exposures.

ENGINEERING:

Because engineers’ jobs can be in any one of the areas above, they must stay alert for all

of the hazards that are listed. Should an engineer get cut while using saws, hand tools or

other equipment they must decontaminate the equipment and any other materials, tools,

etc., that may have become exposed.

FIRST AID:

Employees rendering first aid to guests or other employees should use UNIVERSAL

PRECAUTIONS.

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BLOODBORNE PATHOGENS

PROGRAM CHECK LIST

This check list should be used as a reference guide to ensure that all parts of the program

have been properly implemented. It is a quick and easy reference for the hotel so you

may properly develop an effective program.

PROGRAM LEADER'S GUIDE:

____The program leader's guide was given to the Safety Committee chairperson or

another member of management who is in charge of this program.

____The Safety Committee has reviewed the program leader's guide and developed a

plan of action to execute the program.

____The action plan includes:

The development of a training program based on the hotel's needs and exposures.

Identification of special training needs. This includes names of employees who are

trained in decontamination procedures, types of disinfectant to be used, and PPEs that

will be utilized.

A training schedule for all new and existing employees and names of individuals who

will conduct them.

A review of the video Controlling Exposures to Bloodborne Pathogens or the first

section of the Safety Orientation video.

A plan to identify employee exposures to Bloodborne pathogens.

Disposal of contaminated sharps, bedding or linens.

Cleaning of contaminated equipment or surfaces.

A method to identify exposure incidents.

Determination of whether there has been exposure incidents and if Hepatitis B

vaccinations are currently needed.

Recordkeeping procedures. What records will be needed, how, where, and for how

long they will be stored.

WRITTEN EXPOSURE CONTROL PLAN:

The written control plan has been modified by the hotel to include information needed to

make it fit the needs of the hotel and still conform to federal guidelines.

____The procedures included in the action plan above are included in the written

exposure control plan.

____Methods are in place to ensure all employees are aware of this written program.

____The employees have been given the opportunity to have input into the program.

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____Personal protective equipment is available for employee's use and they are aware of

it and encouraged to use it at all times.

____Personal protective equipment is provided at no cost to the employees and they have

been informed of this.

____Employees have been instructed on how to use and dispose of personal protective

equipment and what it will protect against.

____Employees have been instructed to contact their supervisor or other designated

person if personal protective equipment is defective.

____Procedures are in place to inspect and maintain personal protective equipment.

____Labels and use of red bags or containers are reviewed in this program.

____Procedures have been discussed for the disposal of needles or other contaminated

equipment or materials.

____The vaccination policy has been established and explained to employees.

____Recordkeeping procedures are in place.

____An annual review and update policy has been established.

EMPLOYEE TRAINING RECORDS:

____All employees have signed the employee training record verifying training has been

received.

____All training forms have the signature of the person conducting training.

____Training was given to the employees in a language they understand.

____Classroom sessions were conducted and the employees were given the opportunity

to ask questions about anything they did not understand.

____All training records are kept in a manner that is readily accessible to employees and

management during reasonable hours.

____Employees know who to contact if they want additional information or if they have

suggestions for improvements in the program.

____Procedures have been established to keep training records for at least three years.

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EXPOSURE INCIDENTS:

____Incident investigation and reopen procedures have been established for incident

exposures.

____Investigations will include corrective action procedures to prevent or reduce future

exposures.

____Investigation and report procedures include a review of the use of personal

protective equipment and reasons if this equipment is not used.

____The investigation will identify the source person, if possible. If the source person is

not identified, the reason(s) will be stated in the report.

____When the source person is identified, consent to perform blood testing from this

person will be requested.

____If blood testing is done on the source person, the results will be provided to the

affected employee. The employees have been told that the results of this test are

considered confidential information and only the employee will receive the

results. The employer will not request this information from the employee.

____Employees involved in an exposure incident have been told they have 90 days

following the initial blood collection to decide if they want testing for HIV.

____Procedures are in place to obtain a written opinion from a health care professional

within 15 days. This includes:

The status of the Hepatitis B vaccine.

Post exposure evaluation performance and the employee has been informed of the

results.

Further evaluation or treatment will be provided if needed.

____Procedures are in place to keep employee medical records for the duration of

employment plus 30 years.

HEPATITIS B VACCINATIONS:

____Employees have been informed of their right to receive hepatitis B vaccinations if

there are exposure incidents that indicate a need.

____Employees have been informed these vaccinations will be provided at no cost to

them.

____Employees have been told they can receive treatment at a convenient time and place

for them if there is an exposure incident.

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____The employees understand the hotel will pay for any related travel expenses for

treatment, if necessary.

____If there are exposure incidents and employees refuse the Hepatitis B vaccine, the

declination form has been signed and placed in the files.

____The declination form has not been changed in any way.

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Hazard Communication - HAZCOM (29 CFR 1910.1200)

OSHA's Hazard Communication Program is designed to protect employees from the

hazards associated with chemicals found in the workplace. Each hotel should develop a

program that meets its individual needs.

The program should include the following:

• 
  Chemical inventory.
  
• 
  Purchasing procedures.
  
• 
  Material safety data sheets (MSDS) information.
  
• 
  Container labeling procedures.
  
• 
  Employee training schedules and methods.
  
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  Non-routine hazards.
  
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  Informing outside contractors.
  
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  Designation of a hazard communication compliance officer
  

The name of the compliance officer and the general contents of this program should be

posted on the employee bulletin board at the beginning of the year or whenever there are

changes that effect the program. In addition, the employees should be able to see this

written program anytime upon request.

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Sample

Hazard Communication Program

Hotel Compliance Officer

The compliance officer for this hotel is _____________________________ . All

HAZCOM program activities will be coordinated through the compliance officer and no

changes will be made to the program or procedures without the compliance officer’s

approval. Any employee who has questions or wishes additional information about the

HAZCOM Program should refer their questions to the compliance officer.

The compliance officer will review the MSDS's for chemical hazards and ensure the

necessary safety information is included in all employee training and is presented in a

manner the employees understand. The compliance officer and/or the Safety Committee

should periodically question employees on the chemicals they are using. This should be

done at random with new hires and established employees. The compliance officer

should document these discussions. The compliance officer should obtain new MSDS's

as chemicals are added to the program. He/she should make sure employees are kept

informed of all safety and health information regarding use of chemicals at the hotel. The

compliance officer should have a master file of all chemicals and MSDS's used at the

hotel. These master lists should be made available to any employee who wishes to inspect

them.

At least twice a year, the compliance officer should review - with the Safety Committee -

the HAZCOM program to determine if changes or improvements are necessary. Any

employee may make suggestions to the compliance officer at any time for improving the

HAZCOM Program. The compliance officer should ensure all changes to the program are

dated and the changes are disseminated to the employees. He/she should also keep a

master copy showing the original program along with changes and dates of the changes.

It is part of the compliance officer's duties to ensure the HAZCOM program does not

become static but instead is constantly changing to meet the needs of the employees.

Chemical Inventory

The department heads should be responsible for supplying the compliance officer with an

inventory of all chemicals used in their departments as well as the MSDS from the

vendor. This information should be supplied on the Chemical Inventory Sheet (included

with this program) along with the other requested information. All chemicals used in the

department must be listed. It will be the compliance officer's responsibility to determine

if it is hazardous as defined by law. It will also be the compliance officer's responsibility

to keep the chemical list current and make additions or deletions to the list as needed. No

new chemicals can be used until the compliance officer has been given the name of the

chemical and the MSDS and not before the employees using the chemical have been

trained. The department heads should be responsible for informing the compliance officer

when chemicals are removed permanently from the workplace.

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The compliance officer should review the Chemical Inventory List along with the

MSDS's supplied and complete the Hazardous Chemical List Sheet (attached) for

chemicals deemed to be hazardous. This list should be dated and signed and sent back to

the department head and posted in each department. The master list should be kept by

the compliance officer. As chemicals are added or deleted, the compliance officer will

send out a new dated and signed list to each department. The chemical list will be posted

in each department in a conspicuous manner so the employees can review them at

anytime and during all work shifts.

Purchasing Procedures

The hotel should require that all vendors for chemicals supply the hotel with:

• 
  An MSDS for each chemical
  
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  The containers having the required identification and warning labels.
  

Any supplier or vendor who has not provided this information should be contacted and

asked to provide it or other necessary documentation showing the chemical’s contents. If

the vendor can not or will not provide either, they should be dropped and another supplier

or a different chemical should be used.

Material Safety Data Sheets - MSDS

The compliance officer should be responsible for reviewing the MSDS's to insure they

are acceptable and that the containers include the proper labeling based on the data in the

MSDS. He/she should check the sheets before filing them to be sure they contain at least

the following information:

• 
  The label and information provided must be written in English.
  
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  It must include the identity of the chemical and its common names.
  
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  It must indicate if the chemical is hazardous.
  
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  Information must be provided on the physical and chemical characteristics of the
  
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  hazardous chemical.
  
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  Known short and long term effects of the chemical and related health information.
  
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  Exposure limits.
  
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  Whether it is considered a cancer causing substance.
  
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  Precautionary measures.
  
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  Emergency and first aid procedures.
  
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  The identification of the organization preparing the sheet.
  

The number on the chemical list will be posted on the MSDS so the MSDS for any

chemical can be easily matched up for review by employees. In other words, the

employee can simply find the number and then go immediately to the MSDS for an

explanation of that chemical.

If the employee does not understand the MSDS, the department manager, supervisor, or

the compliance officer should explain it to the employee's satisfaction or contact the

supplier for addition information. If it is determined a chemical is hazardous and the
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MSDS does not have the proper information on safety precautions, the supplier should be

asked to remove the chemical from the property until the proper precautions are

established or another chemical is found.

A master list of all MSDS's should be kept by the compliance officer. This master list

should be kept on the property for at least 30 years. All employees will have the right to

review the master list when requested.

Container Labeling

The department manager working with the compliance officer should verify that all

containers: Are clearly labeled as to the contents; provide all appropriate hazard

warnings; and list the name and address of the manufacturer.

No labels should be removed or defaced unless they are immediately replaced with inhouse

labels. The label should include:

• 
  The name of the chemical and any synonyms.
  
• 
  A signal word such as CAUTION, DANGER, WARNING, FLAMMABLE, etc.
  
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  A statement of the hazard and its severity.
  
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  Precautions and any personal protection equipment needed.
  
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  All first aid procedures.
  

Labels are not required for portable containers when: They are for immediate use; the

chemical was transferred from a labeled container; and it is being used by the employee

who made the transfer. The employee using the unlabeled container should return any

unused portions back to the original labeled container immediately when they are

finished using it. All unlabeled containers not being used should be disposed of

immediately according to hotel policy.

Employee Training & Information

The compliance officer should post his name along with the general content of the

program on the employee bulletin board each January or whenever a new compliance

officer is selected or the program content changes. The department manager or supervisor

should ensure all employees are aware of the program and it is available for their review.

It will also be their responsibility to inform the employees of the location of the MSDS's

and the list of chemicals used by the department.

Employees who use hazardous chemicals as part of their regular duties or when there is a

possibility they may be exposed during an emergency should be trained in the specific

hazards associated with that chemical as well as the safety precautions to follow. There

should be an ongoing program to identify all hazardous chemicals by the Safety

Committee. They should conduct regular inspections of the property in order to identify

hazardous chemicals or employees using chemicals in an unsafe manner. All accidents

involving chemicals should be reviewed by the Safety Committee to determine if there

were previously unidentified hazards which caused or contributed to the accident. If new

hazards are identified, corrective action should be taken immediately and

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additional training provided as needed. The Safety Committee should also review the

program at least twice a year to ensure it is providing the necessary protection for the

employees.

The training for employees who use hazardous chemicals should consist of:

1. Physical and health hazards of the chemical.

2. Visual appearance of the chemical, when appropriate.

3. Odors associated with the chemical, when appropriate.

4. Protective measures that can be taken such as the following:

• 
  work practices
  
• 
  emergency procedures
  
• 
  use of and availability of personal protective equipment
  
• 
  explanation of the labeling system
  
• 
  explanation of the MSDS's
  
• 
  how or who to contact to obtain additional information on the use of
  
• 
  chemicals.
  

The initial training on the use of hazardous chemicals should be done by the compliance

officer who will explain the program content and the basic terms used in the MSDS's.

The specific work methods and detailed explanations on how to use the chemicals should

be supplied by the department manager or supervisor. Employees who receive the

HAZCOM training should sign a form to verify they attended the training and understand

the hazards and precautions as described in the training. A copy of this form is located in

the appendix. Completed forms should be kept in each department by the department

manager with copies sent to the personnel file and to the compliance officer who will

maintain a master list of all training done.

Non-Routine Hazards

When an employee is transferred to another department or is assigned a job that is not

considered part of their normal duties, the supervisor should check to be sure this

employee will not be using a hazardous chemical unless properly trained. If they have

not been trained in the use of a particular chemical, the employee should be given

information about the chemicals following guidelines as mentioned above for training

and information. It should be hotel policy that no employee will begin work until such

training has been provided.

Informing Outside Contractors

Since most work performed by outside contractors will be done in conjunction with the

engineering department, the Chief Engineer or the Assistant Engineer should work with

the contractor to develop procedures to inform them of any hazardous chemicals. This

should be part of the pre-planning for the job. Each department manager should

coordinate efforts with the Engineering department to ensure that the contractor’s

employees are given the information before work begins. The contractor's project

manager and the engineering department should review the work to determine if any

special or unusual chemical hazards will develop or are present because of the work

being performed. At the same time, a plan of action should be developed on how they

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will keep the contractor's workers informed of the chemical hazards present at the hotel.

As a minimum, they should be given the following information:

• 
  Where chemical information is kept for the areas they will be working and who is the
  
• 
  compliance officer for the hotel.
  
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  Where copies of the MSDS's are kept.
  
• 
  Measures that have been taken to lessen the possibility of exposure.
  
• 
  Personal protective equipment available from the hotel and procedures to follow if
  
• 
  they are exposed.
  

It should be the Chief Engineer or the Assistant Engineer's duties to inform and discuss

these procedures with contractors who perform work at the hotel on a regular basis.

When the contractor assigns new employees to perform these tasks, they should be

informed of these procedures as part of the orientation and familiarization of the work to

be performed.

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Frequently Asked HAZCOM Questions By OSHA

In addition to these specific items, OSHA inspectors may ask the following questions in

assessing the adequacy of your program:

Does a list of the hazardous chemicals exist in each work area or at a central location?

Are methods the employer will use to inform employees of the hazards of non-routine

tasks outlined?

Are employees informed of the hazards associated with chemicals contained in

unlabeled pipes in their work areas?

On multi-employer worksites, has the employer provided other employers with

information about labeling systems and precautionary measures where the other

employers have employees exposed to the initial employer's chemicals?

Is the written program made available to employees and their designated

representatives?

If your program adequately addresses the means of communicating information to

employees in your workplace, and provides answers to the basic questions outlined

above, it will be found to be in compliance with the rule.

Compliance Checklist

The following checklist is designed to assist you in complying with OSHA’s HAZCOM

program requirements:

Obtain a copy of the rule. _____

Read and understood the requirements. _____

Assigned responsibility for tasks. _____

Prepared an inventory of chemicals. _____

Ensured containers are labeled. _____

Obtained MSDS for each chemical. _____

Prepared written program. _____

Made MSDSs available to workers. _____

Conducted training of workers. _____

Established procedures to maintain current program. _____

Established procedures to evaluate effectiveness. _____

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General Chemical Safety Rules

1. Proper safety equipment MUST be worn when working with corrosives and

solvents. Proper methods for checking safety equipment should be followed;

safety glasses MUST be worn, rubber gloves should be inspected before each use,

defective equipment should be discarded and replaced immediately.

2. If part of your job is to dispense chemicals, make sure that you have received

proper training for mixing, pouring, and handling them. Use ONLY the correct

disposal methods for each waste chemical.

3. Always read the labels on chemical bottles and them in well ventilated areas. If

you suspect that the ventilation is NOT working properly, immediately notify your

supervisor. Always make sure that proper ventilation is present when handling

chemicals to prevent the accumulation of excessive fumes in the room.

4. Initially treat all spills of liquids as though they might be solvents - Hazard Class -

FLAMMABLE.

5. Do NOT eat, drink, or smoke around chemicals.

6. The immediate First Aid for chemical burns is: Place the affected area under

cold running water for 15 to 20 minutes.

7. In the event of contact with corrosives, use the safety showers and/or eyewashes

which are located in every chemical use area. It is wise to become familiar with

the operation of these systems before an accident occurs, to speed up the washing

of the contact area, and minimize impact of the chemical burn.

8. Always carry acids and solvent bottles in an appropriate container, such as a

bottle carrier, or chemical cart.

9. Check all chemical containers before using them to be sure that the proper

chemical is being used.

10. Wipe up ALL spills and clean your area with water after using acids to avoid

burns.

11. NEVER touch your face or body with your safety equipment on. Remove it and

check your hands before scratching your ear or rubbing your eye, to prevent

injuries.

12. NEVER pour water INTO acid!!! This may cause a violent reaction. Always add

acid SLOWLY into water when this mixture is required.

13. Always rinse safety equipment (especially gloves) and wipe them dry before

removing. This is in case you may have spilled acid on your safety equipment.

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14. Keep highly reactive chemicals separated when is storage (acids, alkalis, and

oxidizers must NEVER be stored near solvents, fuels, or toxic chemicals).

15. Whenever possible, store acids and bases below eye level to minimize the risk of

a splash injury. All chemical containers must be stored with caps or lids tightly in

place.

16. Should skin contact ever occur with any chemical, WASH the affected area

thoroughly and IMMEDIATELY with water. If your clothing comes into contact

with chemicals, change your cloths at once.

17. Make sure that ALL chemical containers are labeled and dated correctly and

accurately with the chemical name, hazard class, and first aid information.

18. Properly discard (and dispose) of old chemicals which may contain unknown

decomposition products.

19. Always have adequate lighting prior to removing chemicals from storage areas.

DO NOT take the chance of selecting the wrong chemical in the dark.

20. Check for sources of ignition before pouring flammable liquids. In the event of

spills, increase ventilation, open the doors and windows. DO NOT operate

lights!!!

21. NEVER MIX two or more chemicals together unless you are completely sure of

the reaction that will occur, and that you can control the results. Many chemicals

will react VIOLENTLY when mixed together. Others will release poisonous

fumes when mixed.

Examples: Flammable Solvent + Acid = EXPLOSION!!!

Flammable Solvent + Oxidizer = EXPLOSION!!!

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