THE ORCBS > Biological Safety > Programs & Guidelines > Exposure Control Plan >

General Program Management

About the MSU Bloodborne Pathogens Exposure Control Plan

Michigan State University is an employer with various groups of employees who have a reasonably anticipated risk of exposure to human blood and other potentially infectious materials when performing their required job duties. As such, MSU must have an exposure control plan in accordance with Michigan OSHA's Bloodborne Infectious Diseases standard. This plan is an administrative document that outlines how this occupational exposure risk will be controlled through the use of administrative controls, engineering controls, work practice controls, and personal protective equipment.

The following document has been prepared by the Office of Radiation, Chemical & Biological Safety (ORCBS) in order to outline the institutional exposure control policies & procedures that will be followed by all affected MSU departments. Due to the diversity of job tasks with associated bloodborne pathogens risk, it must be recognized that information related to task-specific and site-specific procedures may need to be prepared and maintained at the supervisory level along with this institutional exposure control plan in order to fully address regulatory requirements.

Areas of Responsibility
Four areas of responsibility are central to the implementation of the Exposure Control Plan at Michigan State University (MSU) and they include:

1. Exposure Control Officer;
2. Supervisory Personnel (including Department Chairpersons, Directors, Principal Investigators, Managers and Supervisors);
3. Education/Training Coordinators and Instructors;
4. Employees.

Exposure Control Officer

The Exposure Control Officer will be responsible for management and support of the Bloodborne Pathogens Compliance Program. The Biological Safety Officer (or designee) of the Office of Radiation, Chemical and Biological Safety (ORCBS) will serve as MSU's Exposure Control Officer. The Health and Safety Operations Committee and MSU Occupational Health will assist the Exposure Control Officer. Activities delegated to the Exposure Control Officer include:

• overseeing implementation of the Exposure Control Plan;
• developing, in cooperation with administrators, any additional bloodborne pathogens related policies and practices needed to support the effective implementation of this plan;
• revising, updating and improving the Exposure Control Plan when necessary, and on an annual basis;
• collecting and maintaining a suitable reference library related to bloodborne pathogens;
• understanding current legal requirements concerning bloodborne pathogens;
• conducting periodic organizational audits to maintain an up-to-date Exposure Control Plan.

Supervisory Personnel

Supervisory Personnel include Department Chairpersons, Directors, Principal Investigators, Managers and Supervisors. Supervisory personnel are responsible for compliance in their areas. They shall work with the Exposure Control Officer, the ORCBS, MSU Occupational Health and their employees. Activities delegated to the supervisory personnel include:

• assuring that employees in their area who are at risk of exposure to bloodborne pathogens receive initial training and annual retraining (including site-specific training) in bloodborne pathogens as outlined in the "Training" section of this document;
• assuring that all employees receive on-site training regarding engineering controls, work practice controls, personal protective equipment, compliance with safer sharps devices, and proper procedures to follow after an exposure incident;
• evaluating the bloodborne pathogen risk associated with an employee's job classification. This must be done when a new employee is hired, or when an employee changes jobs. This evaluation must include:
• checking the employee's job classification and the tasks and procedures that he/she will perform against the Job Classifications and Task Lists which are identified in the Exposure Control Plan as those in which occupational exposure can occur;
• checking the job classifications and tasks/procedures pertaining to the employees previous position against these lists;
• identifying the new job classifications and/or tasks and procedures which will potentially expose the employee to blood or other potentially infectious materials;
• informing the ORCBS so records can be updated.
• assuring that proper exposure control procedures are followed as outlined in the "Methods of Compliance" section of this document;
• assuring that appropriate personal protective equipment is available and in good working condition for all employees at risk of exposure to bloodborne pathogens;
• assuring that any employee who experiences an occupational exposure incident to blood or other potentially infectious materials is provided with post-exposure medical services as outlined in the "Post-Exposure Evaluation and Follow-Up" section of this document.

Education/Training Coordinator and Instructors

The Education/Training Coordinator and Instructors will provide information and training to all employees who have an anticipated risk of exposure to bloodborne pathogens. The ORCBS Biological Safety Officer (or designee) is the Education/Training Coordinator. The Coordinator will:

• maintain an up-to-date list of MSU personnel that have taken the required initial training and annual retraining;
• develop suitable education/training programs for employees and instructors;
• maintain appropriate training records;
• periodically review the training programs to include appropriate new information.

Training for employees will be offered through the ORCBS. In addition, designated qualified trainers may perform training in their departments. In order to meet MIOSHA regulatory requirements, departmental trainers must observe the following:

• The training must include all mandatory training topics (as outlined in the "Training" section of this document) in all initial training sessions;
• The trainer must generate records of training and submit this information to the ORCBS as outlined in the "Training" section of this document. The trainer must submit an outline of the training curriculum to the ORCBS for review and recordkeeping. In addition, the trainer should keep this information on file for MIOSHA regulatory review if necessary;
• The trainer must actively participate in the Bloodborne Pathogens Train-the-Trainer program (see Appendix E).

For further information regarding MIOSHA's interpretation of bloodborne pathogens trainer qualifications, refer to Appendix E of this document.

Employees

The employees are responsible for following procedures and practices as outlined in the Exposure Control Plan. This includes but is not limited to:

• taking the bloodborne pathogens initial training and annual retraining;
• demonstrating an understanding of which tasks have a potential occupational exposure to bloodborne pathogens;
• conducting all operations in accordance with established work practice controls;
• following universal precautions;
• developing and maintaining good personal hygiene habits;
• reporting all occupational exposure incidents.

Availability of the Exposure Control Plan to Employees

The Exposure Control Plan must be readily available to all employees through their supervisor. Employees are to be advised of the availability of the plan during their education/training sessions. Copies of the Exposure Control Plan are available for each supervisor in areas where exposure to bloodborne pathogens can be anticipated. Employees must have access to this copy of the plan. Although it is not necessary for each employee to have an individual copy, additional copies are available through the ORCBS by request.

Review and Update of the Plan

The MSU Exposure Control Plan will be reviewed and updated:

• annually;
• when new or modified tasks and procedures are implemented which affect occupational exposure of employees;
• to reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens.

Exposure Determination

Exposure Control Plan Table of Contents