Policy Text
University of California, San Francisco
Police Department General Orders
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4.4 Bloodborne Pathogen Rule/Exposure Control Plan
4.4.4 Methods of Compliance (Revised: 8/1/14 )
A number of areas must be addressed in order to effectively eliminate or minimize exposure to
bloodborne pathogens in Department operations. The first five areas addressed in this plan are:
Use of Universal Precautions, Establishing Appropriate Engineering Controls, Implementing
Appropriate Work Practice Controls, Using Necessar y Personal Protective Equipment and
Implementing Approp riate Housekeeping Procedures. Each of these areas shall be reviewed with
employees during bloodborne pathogens related training (see the Information and Training
section of this plan for additional information). By rigorously following the requirements of
OSHA’s Bloodborne Pathogens Standard in these five areas, occupational exposure to
bloodborne pathogens will be minimized or eliminated.
A. Universal Precautions
All human blood and body fluids , such as semen and vaginal secretions , will be handled
as if they are known to be infectious for HBV, HIV and other bloodborne pathogens.
These include cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid,
peritoneal fluid, amniotic fluid, saliva in dental procedures and any body fluid visibly
contaminated with blood. In circumstances where it is difficult or impossible to
differentiate between body fluid types, all body fluids will be assumed to be potentially
infectious. Sergeants are responsible for Insuring compliance with these universal
precau tions.
B. Engineering Controls
A key aspect of the UCSF Exposure Control Plan is the use of Engineering Controls to
eliminate or minimize employee exposure to bloodborne pathogens. Employees shall
clean, maintain and use equipment designed to prevent contact with blood or other
potentially infectious materials to reduce exposures. Sergeants will work with Police
Department managers and other supervisors to review tasks and procedures performed in
operations where engineering controls can be imp lemented or updated. In addition to the
engineering controls identified, the following engineering controls are used throughout
Department operations:
1. Hand washing facilities or antiseptic hand cleansers, towels or towelettes, which
are readily accessib le to all employees who have the potential for exposure and
are located in the First Aid Bag in the trunks of all field personnel vehicles.
2. Containers for contaminated sharps that are:
a. Puncture -resistant
b. Color -coded or labeled with a biohazard war ning label
c. Leak -proof on the sides and bottom and situated to prevent spills.
3. Secondary containers that are:
a. Leak -proof
University of California, San Francisco
Police Department General Orders
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b. Color -coded or labeled with a biohazard warning label
c. Puncture -resistant, if necessary.
C. Work Practice Controls
The f ollowing Work Practice Controls are required as part of the Bloodborne Pathogens
Compliance Program:
1. Employees shall wash their hands immediately or as soon as feasible after
removal of potentially contaminated gloves or other personal protective
equipm ent.
2. Following any contact of body areas with blood or any other infectious materials,
employees shall wash their hands and any other exposed skin with soap and water
as soon as possible. They also shall flush exposed mucous membranes with water.
3. Contaminated sharps shall be placed in appropriate containers immediately or as
soon as possible after use. Refuse sharps shall be placed in red sharps containers
for disposal. Evidentiary sharps will be placed in appropriate puncture -proof
containers with p rovided handling tools.
4. Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact
lenses are prohibited in work areas where there is potential for exposure to
bloodborne pathogens until such time as the area and the contaminated
persons/clothing have been thoroughly decontaminated.
5. Food and drink are prohibited in refrigerators, in freezers, on counter tops and in
other storage areas where blood or other potentially infectious materials are
present.
6. Mouth pipett ing/suctioning of blood or other infectious materials is prohibited.
7. All procedures involving blood or other infectious materials shall minimize
splashing, spraying or other actions that generate droplets of these materials.
8. Equipment that becomes c ontaminated shall be examined prior to servicing or
shipping and decontaminated as necessary (unless it can be demonstrated that
decontamination is not feasible).
a. An appropriate biohazard warning label shall be attached to any
contaminated equipment, i dentifying the contaminated portions, and
b. Information regarding the remaining contamination shall be conveyed to
all affected employees, the equipment manufacturer and the equipment
service representative prior to handling, servicing or shipping.
9. New employees shall be trained in appropriate Work Practice Controls prior to
starting an assignment that places them at risk of exposure.
a. The employee’s job classification and tasks and procedures he/she will
perform is checked against the job classifica tions and task lists identified
in the Exposure Control Plan as those in which occupational exposure
occurs.
b. If the employee is transferring from one job to another within the
Department, the job classifications and tasks/procedures pertaining to the
previous position are also checked against these lists.
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Police Department General Orders
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c. Based on this cross -check, the new job classifications and/or tasks and
procedures that will bring the employee into occupational exposure
situations are identified.
d. The employee is then trained by the PSD Commander or other instructor
regarding any Work Practice Controls with which the