Requirements:
Procedures and Specific Requirements
The following are all job classifications at SLAC in which all employees are at risk of occupational exposure.
The following are contracted employees. As such, they are responsible for adhering to the SLAC ECP in addition to complying with that of their own company.
- Medical Department
- Physician
- Physician assistant
- Registered nurse
- Medical assistant
- Custodial services (contract employee, handling regulated waste)
The following are SLAC employee job classifications that may have occupational exposure:
- SERT member (SLAC employee, providing first aid)
- Custodial services (SLAC employee, handling regulated waste)
- Other employees who perform first aid and CPR as part of their job duties and so may reasonably expected to be exposed to blood-borne pathogens, such as
- Electricians working under the two-man rule (that is, performing high-voltage work, 600 volts or above, see Chapter 8, "Electrical Safety")
- Electricians working on direct current equipment
- Electrical Development and Maintenance (ED&M) Department employees
- SSRL Beamline Electronics Group employees
All employees will utilize universal precautions: all human blood and OPIM will be treated as if known to be infectious for HIV, HBV, HCV, and other blood-borne pathogens.
At-risk employees will receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training.
All employees can review this plan at any time during their work shifts. If requested, employees will be provided with a copy of the ECP free of charge, within 15 days of the request.
The program manager is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure.
Engineering controls and work practice controls will be used to prevent or minimize exposure to blood-borne pathogens. The specific engineering controls and work practice controls used are these:
- Sharps containers
- Hand washing facilities
- Retractable needles
- Safety syringes/monojects
Sharps disposal containers are inspected and maintained or replaced by the Medical Department for the Medical Department. The Palo Alto Fire Department will maintain the sharps containers under their control. Custodial services (both in-house and contracted) and emergency response employees will obtain sharps containers as needed from the SLAC Medical Department and will return them to the Medical Department for disposal whenever necessary to prevent overfilling.
SLAC identifies the need for changes in engineering controls and work practices through review of OSHA records and incident investigations.
We evaluate new procedures and new products at least annually by literature review or information from vendors or discussion with peers in other facilities. If newer or safer products are discovered during this review, steps will be taken to purchase them. All employees are encouraged to make recommendations for changes, updates and improvements to products and procedures.
Subcontractors are responsible for ensuring that these recommendations are evaluated and implemented for their own programs when appropriate.
PPE is provided to SLAC employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is provided by the
Medical Department.
The types of PPE available to employees are as follows:
- Latex or other approved exam gloves
- Splash goggles
- Face shield
- Lab coats
- Face masks
Employees may contact the Medical Department to obtain PPE for use in emergency situations and for spill clean up. Subcontractors will supply their own PPE for routine use, but may contact the Medical Department for emergency situations.
SLAC custodial employees will obtain PPE from their department. SERT members will obtain their PPE from CGS.
See Section Forms & Tools for a guidance on PPE selection and use.
Regulated waste will be placed in containers, to be obtained from the Medical Department or subcontractor as appropriate, that are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see
Labels, below), and closed prior to removal to prevent spillage or protrusion of contents during handling.
See Forms & Tools, for sharps disposal.
Laundry services will not be needed as personnel will use disposable PPE when treating patients and performing tasks that may expose them to blood or OPIM. All contaminated items will be disposed of in red bags and appropriately handled through the medical waste disposal vendor. Red bags may be obtained from the Medical Department. Contaminated items in red bags may be taken to the Medical Department for disposal.
The following labeling methods are used in this facility:
- Red bags appropriately labeled from the manufacturer for contaminated PPE and spill clean up material
- Biohazard labels for specimens in the Medical Department
Custodial personnel, SERT members, and Fire Department personnel are trained and responsible for placing all blood and OPIM items in red bags. The SLAC Medical Department is responsible for ensuring that warning labels are affixed or red bags are used as required if regulated waste or contaminated equipment is brought into the Medical Department. Employees will notify the Medical Department if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, and such without proper labels.
The Medical Department will provide information to its own and SLAC employees on HBV vaccinations, addressing safety, benefits, efficacy, methods of administration, and availability. Subcontractors will provide HBV vaccinations to their own employees.
The HBV vaccination series is available at no cost after initial employee training and within 10 days of initial assignment to all employees identified in the exposure determination section of this plan. Vaccination is encouraged unless
- Documentation exists that the employee has previously received the series
- Antibody testing reveals that the employee is immune
- Medical evaluation shows that vaccination is contraindicated
However, if an at-risk employee declines the vaccination, the employee must sign a declination form (see
Forms & Tools). Employees who decline may request and obtain the vaccination at a later date at no cost.
Documentation of refusal of the vaccination is kept at the Medical Department. Vaccination records will be provided by the Medical Department.
Following the medical evaluation, a copy of the health care professional's written opinion will be obtained and provided to the employee within 15 days of the completion of the evaluation. It will be limited to whether the employee requires the vaccine and whether the vaccine was administered.
Immediate steps, including seeking medical treatment, follow-up, and evaluating circumstances leading to exposure. See
Forms & Tools for sharps disposal.
Medical records are maintained for each at-risk employee in accordance with 29 CFR 1910.1020. These confidential records are kept for at least the duration of employment plus 30 years.
Employee medical records will be provided upon request of the employee or to anyone having written consent of the employee within 15 working days.
The Medical Department is responsible for maintenance of the required medical records for its own and SLAC employees, subcontractors for their own employees.
In addition to the OSHA 300 (29 CFR 1904) record-keeping requirements, all percutaneous injuries from contaminated sharps are also recorded in a sharps injury log. All incidence entries must include at least
- Date of the injury
- Type and brand of the device involved (syringe, suture needle)
- Department or work area where the incident occurred
- Explanation of how the incident occurred
The SLAC Medical Department will contact the Human Resources Department to ensure these injuries from sharps are recorded in the sharps injury log kept by Stanford University. Contractors will maintain a separate log for their employees.
Exposure incidents will be evaluated to determine if they meet the OSHA 300 record-keeping requirements (29 CFR 1904). All exposure incidents will follow the reporting requirements as discussed in the ES&H Manual, Chapter 28, "Accident Investigation". The OSHA 300 log will be maintained by Stanford University for SLAC employees, and be subcontractors for theirs.
Training records are completed for each employee and kept for at least three years by the ES&H Training Group.
The training records include
- Dates of the training sessions
- Contents or summary of the training sessions
- Names and qualifications of persons conducting the training
- Names and job titles of all persons attending the training sessions
Employee training records are provided upon request to the employee or the employee's authorized representative within 15 working days. Such requests should be addressed to
ES&H Training.
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Stanford Linear Accelerator Center, Menlo Park, CA