Student Affairs

    Board of Trustees Policy

    SUBJECT:

    Student, Employee, Patient Occupational Exposure Plan

    		 NUMBER:
    4.4
    DATE:
    November 15, 2004
    SUPERSEDES:
    1995, 9/1997, 6/2004, 10/2004

    Policy

    Current standards of medical and dental practice require a specific plan for written protocols addressing student, employee and patient exposure to blood borne pathogens. Needle stick or other exposure to blood or body fluids has the potential of transmitting various pathogens including but not limited to Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), and Human Immunodeficiency Virus (HIV). In accordance with Federal Occupational Safety and Health Administration (OSHA) and State standards of practice, the following will be implemented in the College-wide Health Career Programs (both credit and non-credit programs) at Montgomery County Community College (herein referred to as the “College”) to manage exposures, record and document exposures and assess incidents in an effort to minimize the opportunity for future exposures.

    Insurance Broker Review: 9/2004
    Legal Review: 9/2004

    1. Protocols for Student, Employee and Patient Exposures

      1. College Students/Patients/Employees

        • An exposure incident as defined by the Centers for Disease Control is a percutaneous injury (e.g., needle stick or cut with a sharp object) or contact of mucous membrane or nonintact skin (e.g., exposed skin that is chapped, abraded, or afflicted with dermatitis) with blood, tissue, or other body fluids that are potentially infectious. In addition to blood, body fluids containing visible blood, semen and vaginal secretions are also considered potentially infectious.

        FIRST AID CARE

        If an individual experiences a needle stick or sharps injury or was exposed to the blood or other body fluid of a patient, another student, or employee, the following first aid care should be done immediately:

        • thoroughly wash needle stick wounds and cuts with soap and water
        • flush splashes to the nose, mouth or skin with water
        • irrigate eyes with clean water, sterile eyewash or saline irrigating solution
        • immediately seek further medical evaluation/treatment

      2. On Campus Incidents

        3. If an individual has an on campus exposure incident involving another student, employee, sharp object or patient, the following actions should be taken:

        • The individual should immediately inform his/her Instructor or immediate Supervisor, and in turn, Public Safety and the College Nurse are to be notified promptly. An Accident/Injury/Illness Report form must be completed (refer to Attachment A). Both the injured individual and the fellow student, employee or patient should be directed to go to the College’s nearest Occupational Health Provider to undergo baseline testing for appropriate blood-borne pathogens (HBV, HCV and HIV) and counseling. The Program Director/Coordinator/Administrator of the respective academic program or College department should be informed.

        • Central Campus — Montgomery Occupational Health
          Located at Montgomery Hospital
          Norristown, PA
          610-270-2555

        • West Campus — Pottstown Occupational Health
          Located at CarePlex at 81 Robinson Street
          Pottstown, PA
          610-326-2300

        NOTE: For College employees, students and patients, the College will pay for the cost of the initial baseline testing and counseling and at the appropriate intervals per the Occupational Health Provider’s protocol. It shall be the Occupational Health Provider’s responsibility to monitor the confidential records and track the testing of individual including reminding the individual when it is time for follow-up testing.

        All costs associated with treatment for disease conditions related to the exposure will be the sole responsibility of the student and the patient. Employees involved in a work related exposure incident requiring treatment will be provided such care through the Worker’s Compensation Program.

      3. Exposure from a Laboratory Specimen

        4. If a student or employee has an exposure incident with a specimen used in an on site campus laboratory, which was collected at a local hospital, the following actions should be taken:

        • The student or employee should immediately inform the Instructor/Supervisor and, in turn, Public Safety and the College Nurse are to be notified promptly. An Accident/Injury/Illness Report form must be completed (see Attachment A). Following this, the person will be directed to go to the College’s nearest Occupational Health Provider to undergo baseline testing for appropriate bloodborne pathogens (HBV, HCV and HIV) and counseling. The Program Director/Coordinator/Administrator of the respective academic program or College department should be informed.

        • The hospital from which the specimen was collected will be requested to contact the patient, from whom the specimen originated, and request he/she go to the College’s nearest Occupational Health Provider to undergo baseline testing for bloodborne pathogens (HBV, HCV and HIV) and counseling.

      4. Off Campus and Contract Sites Incidents

        If a student or employee, in one of the College-wide Health Career Programs, has a bloodborne pathogen exposure incident while at an off campus or contract site, the following actions should be taken:

        • The student or employee is to inform the Instructor/Supervisor at the time of the exposure.

        • If the clinical site is a hospital, the student or employee is to go to the Hospital’s Emergency Department within two to three hours of the incident for evaluation and treatment. A hospital Incident Report form must be completed. The student should have baseline testing completed for appropriate blood-borne pathogens (HBV, HCV and HIV) and treatment options discussed/administered per current CDC protocols. The Program Director/Coordinator/Administrator of the respective program shall be informed and will have the College Accident/Injury/Illness Report (refer to Attachment A) completed and sent to the College Nurse within 24–48 hours. The hospital will contact the patient involved in the episode and request that he or she has baseline testing completed for appropriate blood-borne pathogens (HBV, HCV and HIV) at the hospital. If the patient already has a positive result on file for HIV, then the testing should be done for any other appropriate bloodborne pathogens.

        • At appropriate intervals, student, employee and/or source patient testing following the initial baseline testing will be done through the Hospital’s Occupational Health Provider and paid for by the College. It shall be the Occupational Health Provider’s responsibility to monitor the confidential records and track the testing of individuals including reminding them when it is time for follow-up testing.

        • If the clinical site is not a hospital, the student should be directed to go to the College’s nearest Occupational Health Provider or to the local hospital Emergency Department (whichever is closer) to undergo baseline testing for appropriate bloodborne pathogens (HBV, HCV and HIV) and counseling within two–three hours of incident.

        • For off campus patients/clients involved in an exposure incident with a student or employee in one of the College-wide Health Career Programs, the College will pay only for the cost of the initial baseline testing and counseling and thereafter at the appropriate intervals, per the Occupational Health Provider’s protocol. It shall be the Occupational Health Provider’s responsibility to monitor the confidentiality of records and track the testing of individuals including reminding them when it is time for follow-up testing.

      5. Current CDC Guidelines (June 29, 2001) recommend evaluation and initiation of potential treatment options within 2–3 hours of a incident involving a significant exposure to the blood and/or body fluids of a known HIV positive patient.

      6. In All Cases, Testing Should Occur Within 24 hours of the Incident

      7. Review of Exposure Incident and Identification of Prevention Strategies

        • For each occurrence, the Program Director/Coordinator/Administrator or designee will review the exposure incident with the student and determine what, if any, preventive actions are appropriate to minimize similar incidents in the future. A copy of this information should be forwarded to the College Nurse to be placed with the original Accident/Injury/Illness Report.

        • In an incident involving an employee, Public Safety will review the exposure with the employee and respective supervisor and determine what, if any, preventive actions are appropriate to minimize similar incidents in the future.

        • The College Nurse maintains an exposure injury log book to monitor events and evaluate efficacy of prevention program.

        • The College Nurse in consultation with the Program Director/Coordinator/Administrator or designee will determine: 1) if additional employee/student training is necessary to prevent future occurrences; and 2) if safer medical equipment/supplies is necessary to prevent future occurrences.

      8. Right to Refuse Testing, Counseling and Follow-up

        • lt is recognized that individuals have a right to refuse testing, etc.
        • If the injured student/employee/patient declines to submit to baseline testing and counseling, they will be requested to sign a Waiver Agreement —Release of Responsibility Form (refer to Attachment B).

      9. Record Maintenance and Confidentially

        • Every effort will be made to assure employee, student and patient confidentiality. Bills, records and statements are to be maintained in appropriate confidential files in the Health Career Programs’ confidential files. Information will be released only when appropriate authorization is obtained.

    2. Hazardous Waste

      College policies are followed in regards to collection, disposal and documentation of hazardous waste, including sharps, e.g. needles, glassware, etc. Documentation is maintained in the College’s Business Office. Training for the College’s custodial staff, teaching faculty, and students is the responsibility of the appropriate College Administrator or Program Director/Coordinator or Department Supervisor.

    3. Laundry

      Faculty must wear appropriate gowns/laboratory coats when teaching. Contaminated gowns are handled according to program safety protocols.

    4. Personnel Protective Equipment (PPE)

      All faculty, staff and students will observe the current OSHA guidelines concerning the use of PPE. This includes, when appropriate, gloves, gowns or laboratory coats, face shields or goggles, and masks.

    Bibliography

    Centers for Disease Control Website: www.cdc.gov

    CDC — MMWR Weekly Report: June 29, 2001/Vol. 50/No. RR-11
    (Updated U.S. Public Health Service Guidelines for the Management of Occupational Health Exposures to HBV, HCV, and HIV and Recommendations for Post exposure Prophylaxis)
     
    CDC — MMWR Weekly Report: December 19, 2003/Vol. 52/No. RR -174
    (Guidelines for Infection Control in Dental Health-Care Settings)