Policy Text
University of California, San Francisco
Police Department General Orders
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4.4 Bloodborne Pathogen Rule/Exposure Control Plan
4.4.2 General Program Management (Revised: 8/1/14)
A. Categories of Responsibility
There are four major “Categories of Responsibility” that are central to the effective
implementation of the UCSF Exposure Control Plan. These are the Professional
Standards Unit, Department Managers and Supervisors, Education/Training Instructors
and Employees. The roles played by each of these groups in carrying out this plan are
listed below. Throughout this writte n plan, employees with specific responsibilities are
identified. If, because of promotion or other reasons, a new employee is assigned any of
these responsibilities, the Professional Standards Unit shall be notified of the change so
that the records can be updated.
1. Professional Standards Unit
The Professional Standards Unit is responsible for overall management and
support of the Police Department’s Bloodborne Pathogens Compliance Program.
Activities that are delegated to the Professional Standards Unit typically include,
but are not limited to:
a. Overall responsibility for implementing the UCSF Exposure Control Plan
for the Police Department
b. Working with management and other employees to develop and
administer any additional bloodborne pathogens rel ated policies and
practices needed to support the effective implementation of the plan
c. Maintaining knowledge of current legal requirements concerning
bloodborne pathogens
d. Acting as the Police Department liaison during OSHA inspections
f. Conducting periodic audits to maintain an up -to-date UCSF Exposure
Control Plan.
The Professional Standards Unit will refer to the UCSF Office of Environment ,
Health and Safety (EHS) program, policies and procedures in fulfilling assigned
responsibilities.
2. Department Managers and Supervisors
Managers and supervisors are responsible for enforcement of the exposure control
in their respective areas of assignment. The FSD Captain will assign a Police
Department Safety Equipment Officer to act as an exposure con trol resource, to
maintain supplies, to conduct equipment and compliance inspections (including
the Engineering Control Equipment Review) and to provide training. Managers
and supervisors will work directly with the Professional Standards Unit and
employee s to ensure proper exposure control procedures are followed. Officers
shall inspect vehicles at the beginning of each shift to ensure they are properly
equipped with engineering control and personal protective equipment.
University of California, San Francisco
Police Department General Orders
2
3. Education/Training Instructors
The PSD Commander or designee is responsible for coordinating training for all
employees who have the potential for exposure to bloodborne pathogens,
including:
a. Maintaining an up -to-date list of personnel requiring training
b. Coordinating suitable education/training programs
c. Scheduling periodic training seminars for employees
d. Maintaining appropriate training documentation, such as attendance
rosters and examinations
e. Periodically reviewing the training programs with the Safety Commi ttee
and Police Department managers and supervisors to include appropriate
new information.
4. Employees
Employees have the most important role in the bloodborne pathogens compliance
program, since the execution of much of the Exposure Control Plan is ult imately
their responsibility. Employees must:
a. Know what tasks they perform lead to occupational exposure
b. Complete the online bloodborne pathogens training
c. Plan and conduct all operations in accordance with proper work practice
controls
d. Develop good personal hygiene habits.
B. Availability of the Exposure Control Plan to Employees
The UCSF Exposure Control Plan is available to employees online. Employees are
advised of the plan during their orientation/education/training sessions.
C. Annual Review and Update of the Plan
The training plan will be reviewed and updated:
1. Annually
2. When new or modified tasks and procedures are implemented that affect
occupational exposure to employees
3. Whe n employees’ jobs are revised such that new instances of occupational
exposure may occur
4. When new functional positions within Police Department operations are
established that may involve e xposure to bloodborne pathogens.