Memorandum #308 Infectious Agent and Bloodborne Pathogen Exposure Policy

Revised: December 6, 2021

Purpose and Definition

The purpose of this policy is to describe the management of incidents of exposure to bloodborne or other pathogens or infectious agents that involve Community College of Philadelphia faculty and staff, during the time when they are performing their work activities and for students when they are participating in College activities related to their educational coursework.

Bloodborne pathogens are microorganisms that are present in human blood or other potentially infectious material and can cause diseases in humans (e.g., Hepatitis B, Hepatitis C, and HIV).

An “exposure” that may place an individual at risk to bloodborne pathogens is defined as a percutaneous injury (e.g., a needle stick or cut with a sharp object), contact with airborne aerosols or droplets (e.g., tuberculosis), direct contact or prolonged contact with mucous membranes or contact with skin (especially when the exposed skin is chapped, abraded, or afflicted with dermatitis, or the contact is prolonged or involving an extensive area) with blood, tissues, or Other Potentially Infectious Materials (OPIM) that may result from faculty, staff, and students performing their duties.

Other Potentially Infectious Materials (OPIM) refers to the following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; any unfixed tissue or organ (other than intact skin) from a human; HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions.  Non-intact skin includes skin with dermatitis, hangnails, cuts, abrasions, chafing, acne, etc.

Policy Statement

The following describes the Community College of Philadelphia’s policy developed to manage, record, document, and suppress exposures.

Protocols for Student and Employee Injury and Exposure

Faculty and staff exposed to an infectious agent or bloodborne or other pathogen during the time when they are performing their work activities and students exposed while they are participating in College activities related to their educational coursework must comply with this Infectious Agent and Pathogen Exposure Policy. In this Policy, any student or employee  who is placed in contact with an individual’s blood or other body fluids either on campus or at an approved clinical or laboratory setting off campus must abide by this policy. Such individuals must wear gloves when necessary and also must wear a mask and eye protection when needed.  This policy also includes contact as a representative of the College with clients on campus requiring first aid.

An exposure to an infectious agent will be managed according to the following procedures:

On-campus and Off-campus Incidents at Approved Clinical Sites

1. An injured or exposed student, faculty member or staff member must report the incident immediately to his/her supervisor.  Students must also report the incident to their Faculty Instructor.
2. Immediate first aid should be administered as follows:

• Needle stick injury or cut with contaminated object—Wash the affected area immediately with disinfectant soap and water, followed with treatment as wound indicates.
• Splashes to Skin, Nose, Mucous Membranes or Mouth—Flush with copious amounts of water for at least 3 minutes.
• Splashes to the Eyes—Irrigate with copious amounts of clean water or sterile irrigants for at least 3 minutes.

Student and Employee Protocol for Bloodborne and Other Pathogen Incidents

Any student or employee who has a potential bloodborne or other pathogen injury must seek treatment within two hours of exposure. The following highlights the procedures for students and employees to follow for any suspected or actual pathogen injury. Please note, in all instances, administering first aid and seeking treatment within the requisite time period should take priority. 

The College uses the services of VYBE Urgent Care to treat students and its Workers’ Compensation Providers, including VYBE, to treat employees (see Attachment A for a list of the College’s Workers’ Compensation Providers) who have a suspected or actual pathogen injury. VYBE is located at 1500 Spring Garden Street, Suite R-105, Philadelphia, PA. VYBE’s operating hours are from 8 a.m. to 8 p.m. Monday through Friday and 8 a.m. to 5 p.m. Saturday and Sunday. VYBE’s phone number is 267-768-8288. 

Student Protocol

VYBE will provide appropriate medical care at the first visit and for one follow-up visit. Blood tests will be performed at the first visit to screen for appropriate bloodborne illnesses. If possible, VYBE will also contact the source patient for necessary testing. The cost of the first visit, one follow-up visit and blood tests will be paid by the College. If medication is recommended by the attending physician, the cost of this medication is to be paid by the student.

On-Campus Student Incidents

The Faculty Instructor should immediately notify Public Safety at extension 8111 of the incident. The student will be instructed to go to VYBE. If the individual is unable to walk to VYBE an ambulatory service should be called by Public Safety through 911. Public Safety will fill out the Bloodborne Pathogen Exposure Incident Report and copies of the Bloodborne Pathogen Exposure Incident Report must be retained by Public Safety, sent to the Human Resources Department, the Vice President for Academic and Student Success and the appropriate Deans. 

Off-Campus Student Incidents

The Faculty Instructor should contact VYBE to arrange for the injured or exposed individual to be treated as soon as possible. The on-site Supervisor or Faculty Instructor will fill out the Bloodborne Pathogen Exposure Incident Report and notify the Program’s Clinical Site Supervisor who in turn will notify the appropriate Program Director (Allied Health) or the Department Head (Nursing) of the incident.  Copies of the Bloodborne Pathogen Exposure Incident Report should be sent to the Human Resources Department, the Program Director/Department Head, the appropriate Dean, and the injured or exposed individual. The injured or exposed student will be responsible for presenting a copy of the Bloodborne Pathogen Exposure Incident Report to VYBE.  

Emergency Room

An injured or exposed student has the right to elect to report directly to an emergency room of his/her choosing or to his/her primary care physician if the incident occurred outside of the hours of operation of VYBE. 

Refusal of Treatment

An injured or exposed individual has the right to refuse treatment. If an individual refuses care, he/she must sign a refusal waiver form located on the back of the College's Bloodborne Pathogen Exposure Incident Report. The form must be signed by the individual immediately following the injury or exposure. Copies of the waiver form for a student must be retained by the on-site Clinical Supervisor, the Program’s Clinical Site Supervisor, the Program Director/ Department Head and the injured or exposed student. If treatment is refused, a clinical site may refuse to permit the student to continue to report to the clinical site and this could result in dismissal from the program for the exposed student. 

Faculty/Staff Protocol

The Workers’ Compensation Provider will provide appropriate medical care that will be covered under the College’s Workers’ Compensation Program. Blood tests will be performed at the first visit to screen for appropriate bloodborne illnesses. If possible, the Workers’ Compensation Provider will also contact the source patient for necessary testing. The cost for all visits, blood tests and medication will be paid through the College’s Workers’ Compensation Program.

On-Campus Faculty/Staff Incidents

The employee should notify their immediate supervisor of the incident. The Immediate Supervisor will notify Public Safety at extension 8111 of the incident. Public Safety will fill out the Bloodborne Pathogen Exposure Incident Report and a copy must be retained by Public Safety and a copy sent to the Human Resources Department. A copy of the report will also be given to the injured or exposed individual who will be directed to the nearest available Workers’ Compensation Provider for the College (see Attachment A).   

Off-Campus Faculty/Staff Incidents

The employee must notify the on-site supervisor. The on-site Supervisor will fill out the Bloodborne Pathogen Exposure Incident Report and notify the Program’s Clinical Site Supervisor who in turn will notify the appropriate Program Director (Allied Health) or the Department Head (Nursing) of the incident. Copies of the Bloodborne Pathogen Exposure Incident Report should be retained by the Human Resources Department, the on-site Clinical Supervisor, the Program’s Clinical Site Supervisor, the Program Director/Department Head and the injured or exposed individual. The on-site Supervisor may contact the nearest available Workers’ Compensation Provider for the College (see Attachment A) to arrange for the injured or exposed individual to be treated as soon as possible. The injured or exposed individual will be responsible for presenting a copy of the Bloodborne Pathogen Exposure Incident Report to the Provider.

Emergency Room

An injured or exposed faculty/staff member should report to the nearest available Workers’ Compensation Provider during its operating hours (see Attachment A). If the incident occurs after normal operating hours or if the injured or exposed faculty/staff member is not within reasonable distance of a Workers’ Compensation Provider, the faculty/staff member should report to the nearest emergency room. The cost will be covered by the College’s Workers’ Compensation Program.

Refusal of Treatment

An injured or exposed individual has the right to refuse treatment. If an individual refuses care, he/she must sign a refusal waiver form located on the back of College's Bloodborne Pathogen Exposure Incident Report. The form must be signed by the individual immediately following the injury or exposure. Copies of the waiver form for a faculty/staff member must be sent to the Benefits Office in the Human Resources Department. If treatment is refused, a clinical site may refuse to permit the faculty member to continue to report to the clinical site.

Injury Protocol

1. Protocol for injury is usually:
   1. Identification and documentation of the source individual. Documentation should include: route of exposure, circumstances under which exposure occurred, PPE in use, work practices, location of incident and procedure being performed. Public Safety will be responsible for the initial injury report. HR will receive a copy and record the injury with the workers compensation insurance carrier.
   2. Testing the source individual as soon as feasible to determine Hepatitis B, Hepatitis C and HIV infectivity.
   3. Counseling should be provided to the injured party to discuss recommendations for treatment, follow-up care and testing and the EAP can be utilized for employees. Students should be directed to the Counseling Center. Employees should be directed to Human Resources with any concerns.
   4. Prophylaxis treatment (e.g., HIV, hepatitis, etc.) should be initiated within two hours of exposure.
2. Certain clinical sites may have established policies for treatment of injuries or an exposure to pathogens. Injured or exposed individuals may elect to follow such policies, but the Bloodborne Pathogen Exposure Incident Report must still be completed and sent to the appropriate individuals as stated above.
3. An injured or exposed individual has the right to refuse treatment. If an individual refused care, he/she must sign a refusal waiver form on the back of the College’s Bloodborne Pathogen Exposure Incident Report. The form must be signed by the individual immediately following the injury or exposure. Copies of the waiver form should be retained by Public Safety and Human Resources. If treatment is refused the College may refuse to permit the individual to return to campus and/or the clinical site for a stipulated period of time based upon an assessment of the threat of harm to the individual or others.

Cases of Self-reported or Suspected Infections

An individual who suspects they have contracted an infectious illness (e.g., MRSA, TB, COVID-19) or who suspects they could be in direct contact with someone who has an infectious illness should follow the guidelines as stated below.

1. Students, who are self-reporting, reporting the suspected illness of another individual or employees who suspect a student is infected, should state their concerns to the Dean of Students. The Dean of Students (Room S2-10) will take the appropriate steps to determine the accuracy of the information. If an incident of infectious illness is confirmed, the infected individual will be asked by the Dean of Students to seek medical attention from his/her own physician. In PA, the state does not require individual incidents of MRSA to be reported to the Health Department. Also, students are not restricted from attending school as long as the wound is covered and the student is receiving treatment.
2. Employees who are self-reporting or reporting the suspected illness of another individual should state their concerns to their immediate supervisor. If an incident of infectious illness is confirmed, the immediate supervisor will contact Human Resources. Human Resources will contact the infected individual and ask that he/she seek medical attention from his/her own physician.

3. Students or employees who suspect they have contracted or been exposed to COVID-19 should follow the College’s Protocol for Suspected or Confirmed COVID-19 on Campus.

Clearance

Any individual who has been exposed to an infectious or bloodborne pathogen must present evidence of his/her ability to return to work, to school, and to any clinical site according to the following protocol:

1. Students in Nursing and Allied Health Programs should present the information to the Department Head (Nursing) or Program Director (Allied Health). The Department Head or Program Director will be responsible for informing the clinical site that the student has been cleared and may return to the clinical site.
2. Students who fail to provide such clearance may be administratively withdrawn from a program if they are unable to return to class and/or complete their clinical assignment. Students not enrolled in Nursing and Allied Health Programs should present the information to the Dean of Students.
3. Faculty and staff must present information to the Human Resources Department. A statement from the attending physician which clears the employee to return to work is required or the employee will not be permitted to return to work without a clearance notification from the attending physician.

Record Keeping

The Bloodborne Pathogen Exposure Incident Report and all pertinent records will be considered confidential and they will be kept for 30 years. Records for employees will be kept in the Human Resources Department. Nursing and Allied Health student records should be kept by the respective Nursing and Allied Health Department Heads or their designee. Records for other students should be kept by the Dean of Students.

Attachment A

Occupational Clinics/Urgent Care Vybe Urgent Care 1550 Spring Garden Street Suite R105 Philadelphia, PA 19130 (267) 768-8288	Hospital Thomas Jefferson University Hospital 111 S 11th Street Philadelphia, PA 19107 (215) 955-6000
Occupational Clinics/Urgent Care Worknet Occupational Medicine 216 N Broad Street Mail Stop 101 Philadelphia, PA 19102 (215) 762-8525