Labels, Training, and Recordkeeping
13.0 Labels
Warning labels will be attached to containers of regulated waste, and refrigerators, freezers, storage containers, transport containers and shipping containers that contain potentially infectious materials.
Labels will have the orange, orange/red biohazard warning symbol on them with contrasting lettering, as depicted:
Red bags or red containers may be substituted for labels.
The only exceptions are:
- Containers of blood, blood components or blood products that are labeled as to their contents, and have been released for transfusion or other clinical use.
- Individual containers of potentially infectious materials that are placed into a labeled secondary container during storage, transport, shipment or disposal.
Laboratories are directed to the Biosafety Manual for additional labeling and signage requirements.
14.0 Training
Occupationally exposed employees will be trained at the time of their initial assignment to at-risk work and annually thereafter. As applicable, the training will include both general EHS training and Campus Unit specific training. This training will be provided at no cost to the employees during work hours. Employees new to the BBP program, who are unable to attend an EHS pre-scheduled training session, are instructed to contact EHS to make other arrangements. The annual refresher training may be completed by attending a scheduled EHS session or through the EHS online program. All training will be provided with content and vocabulary appropriate to the employees receiving the training.
Training provided by EHS will include the following, in compliance with current OSHA training requirements. Campus Units may choose to conduct these training sessions in house; in which case the training must meet current OSHA requirements, and be document according to the requirements in section 15.0.
- Access to the OSHA standard and explanation of it鈥檚 contents
- Epidemiology and symptoms of bloodborne diseases
- Modes of transmission of bloodborne pathogens
- 91原创's Bloodborne Exposure Control Plan, including how to access it
- Procedures for recognizing tasks that might involve exposure to potentially infectious materials
- Control methods and their limitations (work practices, engineering controls, PPE, training, etc.)
- Personal protective equipment, including basic types, use and selection
- Procedures to follow in an exposure incident
- Post-exposure evaluation and follow-up
- Signs and labels
- Hepatitis B vaccine program
- An opportunity for questions and answers
Annual retraining will include any adjustments made to the program in the last year, any new regulatory or technical information, and information on any new equipment or devices introduced into the workplace during the past year.
In addition to formal classroom training, all Campus Units will provide on-site training in the work setting including specific procedures and equipment location, particularly to new employees or those in new roles or using new equipment. Additional training must be provided when changes to tasks, procedures or equipment affect employee鈥檚 occupational exposure.
15.0 Recordkeeping
Training Records
Training Records will include:
- Dates of the session.
- Contents or summary of session.
- Name and job title of all attendees.
- Names and qualifications of persons conducting training.
Training records will be maintained for 3 years from the date that training occurred. EHS will maintain records of all EHS conducted training. The Campus Unit will maintain records of the training conducted by their employees; Campus Units may also maintain records of EHS training.
These records will be made available to the Chief of the State of Ohio Department of Industrial Relations upon request. Training Records will be provided upon request for copying to the subject employee, anyone having written consent of the subject employee, and Chief of the Department of Industrial Relations in accordance with 29 CFR 1910.1020.
Employee Medical Records
Employee Medical Records will be kept by the Occupational Health Clinic and will include:
- Name and social security number
- Copy of staff member's Hepatitis B vaccination status, including the dates of all vaccines, and any medical records relating to the employee's ability to receive the vaccination.
- A copy of all results of examinations, medical testing, and follow-up procedures for exposure incidents.
- Copies of the health care professional's written opinion.
- Copy of information provided to the health care professional as part of an exposure incident.
Confidentiality is to be maintained. The employee's expressed written consent is required for release of any medical record to any person within or without the workplace except as required by law. 91原创 will maintain medical records for at least the duration of employment plus 30 years. All medical records will be maintained in accordance with local, state and federal regulations.
Sharps Injury Log
Each Campus Unit will report all sharps injuries using the state of Ohio Needlestick Report Form. The needlestick report form is a State of Ohio requirement separate from the BBP sharps injury log; however, the needlestick report form will be used to generate the sharps injury log. EHS will maintain the sharps injury log in accordance with OSHA regulations:
- Employees will not be identified:
The log will include:
- The type and brand of device involved
- The campus unit or work area where the exposure incident occurred
- An explanation of how the incident occurred
- The log will be kept in accordance with 29CFR1904.6.
16.0 Annual Program Review
Annual program review of the university-wide Bloodborne Pathogens program by the Department of Environmental Health and Safety
| Date | Name of Evaluator | Changes (yes/no) | If yes, what changes were made |
|---|---|---|---|