Current Exposure Control Plan
The Occupational Safety and Health Administration (OSHA) regulates facilities where employees may be exposed to bloodborne pathogens (BBP). The City of Portland is committed to promoting safe work practices to minimize exposure and the incidence of disease caused by these pathogens.
The City conducts operations, which may result in employee exposure to BBP. The City is committed to ensuring that employees who are at risk of exposure are:
- identified and trained
- provided with tools and resources
- provided appropriate medical attention
The purpose of this policy is to establish framework for the City’s compliance with OSHA Rules governing BBP in the work place. This policy also provides BBP information to City bureaus and employees.
- The City takes measures to comply with the regulations and statutes that protect employees from BBP. This is achieved through:
- Identifying employees at risk of exposure by analyzing the type of work they perform;
- Making Hepatitis B vaccinations available to employees with occupational exposure;
- Training affected employees in the dangers of bloodborne, preventative measures and exposure procedures;
- Instituting engineering and administrative controls to eliminate or reduce potential exposure and conduct annual inspections;
- Provide employees with adequate tools, equipment and resources to protect themselves against exposure;
- Adoption of the City’s Exposure Control Plan.
This policy applies to all City bureaus and employees who face a reasonably anticipated risk of exposure to BBP in the course and scope of their work.
Authority and Compliance
Authority is provided under:
- City Code 3.54.020, OMF Risk Management Division Responsibilities and Authority
- BHR Administrative Rule 2.03 ;Bloodborne Pathogen Exposure and the Workplace
- Division 1, General Administrative Rules, Rules for the Administration of Loss Prevention Activities by Insurers/Self-Insured Employers – General, General Requirements Chapter 437-001-1020
In compliance with:
Bureau of Human Resources
BHR is responsible to:
- Develop and maintain an Exposure Control Plan in compliance with OSHA Rules;
- Provide leadership, consultative services and technical expertise to City bureaus and employees;
- Staff an Occupational Health and Infectious Disease Program Manager position whose duties include:
- Providing BBP training to City employees,
- Providing training resource information and assisting with inter-bureau coordination of educational programs,
- Providing Hepatitis B vaccinations, post exposure evaluation and follow up.
Bureaus are responsible to:
- Ensure that a copy of the City’s Exposure Control Plan is accessible to employees;
- Provide City Risk’s Occupational Health and Infectious Disease Program (OHIDP) Manager with information about any change in technology that will eliminate or reduce exposure to BBP;
- Manage City Risk’s Exposure Control Plan within their respective bureaus and comply with all duties owed to employees by an employer including, but not limited to:
- Ensuring that employees have received training;
- Provide employees with equipment, supplies and personal protective devices with which to prevent and protect against exposure to potentially infectious materials during work;
- Ensure that employees use the appropriate equipment, supplies and personal protective devices when responding to an incident involving exposure to potentially infectious materials;
- Providing hand washing facilities and supplies so that in the event of exposure, employees may sanitize exposed skin and tissues;
- Direct employees through the appropriate process and procedure for Hepatitis B vaccinations in a timely manner;
- Where feasible, maintain housekeeping sufficient that the work site is kept clean and sanitary;
- Properly clean and sanitize areas contaminated with potentially infectious materials;
- Properly collect and dispose of all waste that is contaminated with potentially infectious materials;
- Investigate, assist and provide City Risk’s OHIDP Manager with any needed information;
- Record an exposure incident on its 300 Log within seven days of the event and ensure confidentiality by recording the incident as a privacy case;
- Where applicable, maintain a Sharps Injury Log; and,
- Collect and maintain an accurate record for each employee with occupational exposure.
Note: Portland Fire & Rescue, Portland Police Bureau, and the Bureau of Environmental Services have a separate stand alone Bloodborne Pathogen Policy and Program.
Employees are responsible to:
- Identify and report potential BBP hazards.
- Wear required PPE.
- Attend BBP training as assigned.
- Apply BBP training received to the job.
- Follow established safe work practices for minimizing exposure to BBP.
References and Resources
Related City programs and policies include the following:
- Bloodborne Pathogen Program Guideline
Attachment A - Job Classifications at Risk for Exposure
Employees subject to the OR-OSHA bloodborne pathogens standard are those who are reasonably expected to have skin, eye, mucous membrane, or parenteral contact with blood and/or any body fluids that are contaminated with blood resulting from the performance of their assigned job duties. Listed are Job classifications and associated tasks identifying employees at risk of exposure to blood or other potentially infectious materials. Exposure determinations are made without regard to use of PPE.
|Job classification||Task or Exposure|
|Employees at risk – OMF Risk Management|
|Occupational Nurse||Nursing assessment; phlebotomy; lab processing, injections|
|Employees at risk – Police Bureau|
|All Sworn Officers||Dealing with public, police duties|
|Evidence Control Specialists||Evidence processing and storage|
|Precinct Desk Clerks||Dealing with public, contaminated items turned in|
|Auto Servicers||Working with contaminated vehicles|
|Employees at risk – Bureau of Environmental Services|
|Industrial Maintenance Millwrights (IMM)||Maintain waste water system, respond to overflows|
|IMM Apprentices||Maintain waste water system, respond to overflows|
|IMM Operators||Maintain waste water system, respond to overflows|
|Wastewater Treatment Operators, Special Operations Group||Maintain system, respond to pump clogs|
|Pollution Control Lab (PLC)||Clinical lab specimen handling|
|PLC Field Operations Staff||Collection of water and other samples|
|Employees at risk – Portland Parks and Recreation|
|Lifeguard||First aid and CPR|
|Employees at risk – PBOT Portland Streetcar|
|Utility Worker I||Cleans and maintains streetcars; cleans body substance spills|
Attachment B - Engineering & Work Practice Evaluation Form
Attachment C - PPE Declination Exposure Incident
Attachment D - Hepatitis B Vaccine Declination
Attachment E - Communicable Disease Guidelines
City of Portland Bloodborne Pathogen Program Communicable Disease Guidelines
|Exposure Level||Exposure Description||Action Required|
|Level 1||Contact limited to being in the presence of a person suspected of having a communicable disease.||No special action required unless the person has, or is suspected to have, an airborne disease such as TB or meningitis. Follow airborne exposure guidelines.|
|Level 2||Contamination of intact skin, clothing, or equipment with blood and/or body fluids.||Follow decontamination procedures, such as hand washing and laundry requirements.|
|Level 3||Exposure of open skin cuts or breaks, mucous membranes, such as eyes, nose, or mouth, to blood or body fluids. This includes needle stick and human bites.||Follow action outlined in bloodborne exposure guidelines.|
Attachment F - Exposure Incident Report Sample
Attachment G - Occupational Exposure Worksheet
Attachment H - Information Sheet for Body Fluid Exposure
You have had an exposure to someone’s blood or body fluid. We recommend that lab tests be done to document your current (baseline) serum antibody levels for Hepatitis B, Hepatitis C and HIV.
The likelihood of disease transmission, although small, is real. If your “source” person is positive for HIV antibody, there is still only a 0.3% risk of transmission to you. If the “Source” is positive for Hepatitis B antigen, disease transmission may be as high as 40%, unless you are already immune to Hepatitis B. Disease transmission for Hepatitis C is approximately 2%-10%. Some factors i.e., the use of gloves, shallow penetration and size of the needle/sharp, and age of the needle may decrease the exposure magnitude.
Precautions-just in case
- Practice safer sex, use condoms
- Don’t share razors, tooth brushes or needles
- Don’t donate blood, semen or tissue until your antibody levels are negative 6 months after the exposure
- You will be notified of your lab test results within a week
- If the “source” person is tested, then you will be notified of their lab results as soon as possible. You must keep their lab results confidential
- After baseline labs, we generally repeat labs at 6 weeks, 3 months and 6 months.
- HIV Conversion Syndrome (2 weeks to 6 months incubation) symptoms may include fever, sore throat, muscle and joint pain, enlarged lymph nodes, and rash
- Hepatitis B (45-180 day incubation) insidious onset of symptoms may include loss of appetite, abdominal pain, nausea, vomiting, joint pain, rash or jaundice (yellowing of the skin)
- Hepatitis C (2 weeks to 6 months incubation) insidious onset of symptoms may include loss of appetite, abdominal pain, nausea, vomiting, joint pain, or jaundice (yellowing of the skin)