BLOOD BORNE PATHOGENS CONTROL PLAN
POLICY & PURPOSE
It is Zoetis Union City Policy to comply with regulatory requirements pertaining to the Exposure Control Plan, and require workers to adopt safe work practices and implement procedures for the safe handling, storage, and disposal of blood and human-derived products.
The purpose of this Plan is to define safety policies and procedures for handling human blood and all human-derived materials, and Other Potentially Infectious Material (OPIM). This Plan also serves as a resource and guidance document for workers with regard to safe work practices.
This Plan complies with the regulatory requirements of the OSHA Bloodborne Pathogens (BBP) Standard (Title 8 CCR, Section 5193) and intends to provide guidance for handling these agents in accordance with accepted practices as defined in the Zoetis Union City Biosafety Manual.
RESPONSIBILITIES
The EH&S department and Safety Committee are actively involved in determining the appropriate safety provisions related to each procedure listed above. All colleagues are encouraged to contribute and participate in safety.
TRAINING
Colleagues are provided with a copy of this Plan and training dedicated to the Biosafety and the BBP Programs. Colleagues who work with human blood, blood controls, or OPIM must attend all required training programs, including an annual refresher course on BBP.
When procedures change or a project involves a newly introduced pathogen, the supervisor will conduct informal safety discussions with lab staff.
At a minimum, all personnel working with blood and OPIM must be trained in the following areas as soon as possible after starting work at Zoetis Union City:
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The components of the Zoetis Union City Exposure Control Plan
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Uses, limitations of, and procedures for using personal protective equipment
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A discussion of the HBV vaccination series, including the benefits of vaccinations and efficacy of the vaccine in preventing disease
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Safe handling methods for potentially infectious or viable agents
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Proper methods for transporting infectious agents and other bio-hazardous materials
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Emergency procedures involving blood exposure or contamination
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Post-exposure follow-up procedures
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Hazard communication
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Bio-hazardous waste management
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Evaluation of colleague understanding of the Plan
ANNUAL TRAINING
Bloodborne pathogen training will be conducted annually for all job classifications listed in this Plan. The training will include, but not be limited to the following topics:
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Biosafety Levels
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The Abaxis Bloodborne Pathogens Program
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Primary and Secondary Containment
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Good Laboratory Practices
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Hepatitis B Vaccination Program
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Waste Disposal
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Spill Clean-up
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Results from the evaluation of engineered sharps protection
Annual training classes are conducted to update colleagues on changes to the program and to inform them of changes in newly introduced processes, and changes to sharps handling practices. Annual training also addresses the evaluation of engineering controls and new technologies in containment methods.
Supervisors are responsible for ensuring that their direct reports attend all required training programs and that colleagues understand their responsibility for safety compliance.
PROGRAM REQUIREMENTS
Program requirements are determined by OSHA and CAL/OSHA. This section includes the following:
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EXPOSURE CONTROL PLAN
Colleagues who handle human blood and its derivatives and OPIM are required to read this Plan and become fully familiar with Universal Precautions and the requirements of the Bloodborne Pathogens Program. The Plan also describes methods for the storage and disposal of human blood and OPIM.
The Bloodborne Pathogens Plan applies to all colleagues who might come into contact with blood or other bodily fluids including:
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Human blood
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Human blood components
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Products made from human blood, or other potentially infectious materials (OPIM)
The Bloodborne Pathogens Standard requires that the Exposure Control Plan is effectively implemented and that it contains the following elements:
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Policies and procedures for elimination or minimization of exposure
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Evaluation of the potential for colleague exposure
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Medical surveillance program
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Routine training (at least annually)
The Exposure Control Plan is reviewed at least annually and is modified to reflect changes in the following:
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Regulatory requirements
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New or modified tasks, procedures, and processes
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New equipment, especially sharps, including needles, needleless systems, and other engineered sharps protection
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New or revised job descriptions which involve the handling of Bloodborne pathogens
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Exposure and injury incidents involving Bloodborne pathogens
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Identified deficiencies in the Exposure Control Plan
The EH&S Department and Safety Committee members will review and authorize all changes to the program including a review of engineered sharps protection and the possible use of needleless systems. They will also review and authorize procedures involving blood that meet best management practices.
EXPOSURE DETERMINATION
Colleagues who are covered under the Bloodborne Pathogens Program are identified as potentially at-risk colleagues based on their job definitions and work locations. Zoetis Union City conducts exposure determinations beginning with new colleague safety orientation and from information provided by work area managers. Colleagues who are identified as participants in the program are enrolled in the Hepatitis B vaccination (HBV) program. They will be trained initially, and again at least annually, in the provisions of the BBP Program.

Several departments have colleagues who may potentially be at risk even though they do not perform activities and procedures involving Bloodborne pathogens (mostly by visiting areas where BBP may be present). Other colleagues may enter work areas occasionally to observe procedures, service equipment, or donate blood for clinical trials (any colleague). In such cases initial BBP training is suggested for general awareness.
UNIVERSAL PRECAUTIONS
Complying with the requirements of the OSHA Bloodborne Pathogens Standard requires that colleagues understand and follow procedures known as Universal Precautions.
Universal Precautions are work practices and procedures which, when implemented, help prevent exposure to blood and OPIM. Universal Precautions follow a standardized approach of treating all human-derived fluids as being contaminated, and therefore capable of transmitting diseases. The following describe methods for implementing Universal Precautions:
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Engineering Controls: As discussed in the Biosafety Manual, primary and secondary containment are a component of the Abaxis Exposure Control Plan and employ engineering controls and facility design as strategies in exposure control.
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Administrative Controls: Also discussed in detail in the Biosafety Plan, these are work practices and procedures intended to separate the user from a potentially infectious agent or to prevent exposure to contaminated materials. These include the following.
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Good personal hygiene: Wash hands and exposed skin immediately if contaminated with blood or OPIMs to which universal precautions apply.
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Wash hands immediately after removing gloves. Miniscule holes and punctures are not easily observed and present a pathway for contamination.
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Sharps handling techniques: Syringe needles must be used one time only and must be disposed of in a labeled biohazardous sharps waste container immediately after use.
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Decontamination of Spills and Splashes: Clean up spills and accidents as soon as they occur. The Emergency Action Plan discusses spill cleanup in greater detail.
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Bio-hazardous Waste Disposal: Dispose of waste in rigid hard-walled waste containers that are clearly marked with the universal biohazard symbol. Waste containers must be covered when they are not in use.
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Sharps Disposal: Contaminated sharps indicate that a risk of exposure exists. Use needles with engineered sharps protection, as required. Dispose of used sharps in a sharps container immediately after use.
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Personal protective equipment: Standard PPE includes lab coats or smocks, gloves, and eye protection. PPE is a primary barrier intended to help prevent exposure from blood or OPIM to open wounds and mucous membranes, including the eyes. When working with whole blood and OPIM, safety glasses are required as protection against splatters and spills even if you are working at the biosafety cabinet. If you are unsure whether the level of protection is adequate, ask the EH&S Department for recommendations.

HAZARD COMMUNICATION
Effective use of warning signs and labels is important in conveying information regarding the locations where potentially pathogenic agents are being handled. The following methods are used by Zoetis Union City to warn colleagues of Bloodborne pathogen hazards:
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Waste containers are labeled with the universal biohazard symbol
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Biohazard labels are affixed to storage equipment (e.g., freezers and refrigerators, incubators, etc.) or any other area where potentially infectious materials are stored or handled.
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Biohazard signs are posted on the entrance to work areas that operate under Biosafety Level 2 containment. The sign should include the biohazard symbol, name of the agent(s) handled in the work area, special entry requirements, and the telephone number for a 24-hour contact.
MEDICAL SURVEILLANCE
The Cal-OSHA Bloodborne Pathogens Standard requires that all colleagues with potential exposure to Bloodborne pathogens be offered immunization against the hepatitis B virus (HBV).
Any colleague (regular or temporary) who chooses not to be immunized for HBV is required to sign a declination form stating this intent. This declination form must remain with the employer through a colleague's tenure at Zoetis Union City and then for another 30 years.
HBV VACCINATIONS
As a requirement of the OSHA Standard, colleagues who are assigned to work with human-derived products must be offered immunization against the hepatitis B virus (HBV). During New Hire BBP Safety Orientation, colleagues will be provided with the information necessary to receive the HBV vaccination series or a titer test to confirm antibody protection. Approximately one month after completing the series of immunizations, colleagues should have their titers tested. In select cases some colleagues may not develop a surface antibody to HBV and these colleagues will be informed of their status. Elements to the HBV vaccination are provided below.
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HBV vaccinations include three shots; the first is given upon an worker’s introduction to the program, another shot is given approximately one month later, and the final immunization is given 5 months after the second shot
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Colleagues who have previously received the series of shots may have titer tests at the Zoetis Union City occupational health provider, or provide verification of protection to EH&S.
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HBV vaccinations and titer tests are provided at no cost to colleagues
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Colleagues who choose not to have a titer test or vaccination must indicate their declination on the Hepatitis B Vaccine Declination Statement; this form must be retained on file by EH&S for a period that encompasses the duration of the colleague's employment plus five (5) years. A colleague who declines the HBV vaccination may, at any time thereafter, change his or her mind and receive the vaccine
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Titer tests are provided approximately one month after the completion of the vaccination series to verify if a conversion of HBV surface antibody occurred.
INCIDENT REPORTING
All exposure incidents must be investigated and documented and the exposed colleague(s) must be provided with medical attention immediately after exposure. Incidents involving exposures through breaks in the skin or via mucous membranes and the eyes must be reported immediately. This is an important step in providing exposed colleagues with the fastest and most appropriate medical treatment possible.
In the event of an exposure to blood or OPIM by needle stick puncture or through an open wound, use the following procedures:
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Bleed the wound as much as possible by quickly going to the sink, squeezing the wound or puncture and allowing the blood to help cleanse the wound
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Wash the wound with soap and running water for at least 15 minutes. Meanwhile, co-worker should call the Zoetis Union City occupational health provider.
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Inform the receptionist on the phone about the nature of the injury, the time it happened, the severity, and most importantly the source agent of exposure
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Take a sample of the source agent, if requested, to the health care provider.
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Report the injury to the colleague's supervisor and to the EH&S department. This will be transcribed to the WIR.
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Transport the colleague to the health care provider to prevent them from suffering trauma while driving
Injured colleagues are required to report the incident immediately to the supervisor or the EH&S department. According to Zoetis Union City policy, an incident investigation (analysis) will be completed on an IIR. If the incident involves a sharp, then OSHA requires that a Sharps Injury Log be completed. The Sharps Injury Log is provided by the EH&S department, or designee.
POST-EXPOSURE FOLLOW-UP
Post-exposure follow up is available to all colleagues who have had an exposure to Bloodborne pathogens. Zoetis Union City vendor will provide serologic testing, post-exposure prophylaxis, if appropriate, and counseling by a physician.
All subsequent counseling, guidance, monitoring, and health services will be provided at no expense to the colleague, held in the strictest of confidence, and maintained in confidential medical records in separate personnel records.
MANAGING CONTAMINATED LAUNDRY
Laundry that is soiled by blood or OPIM must be handled appropriately. Safe work practices dictate that soiled PPE not be taken home, but laundered by a commercial firm. Laundry companies must know if a lab coat or other clothing is soiled with contaminants as protection to their workers. As a result, the following procedures apply when blood or OPIM is spilled on a lab coat and/or smock, or if the lab coat is otherwise stained or soiled by such materials.
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Place the soiled lab coat in a red biohazard waste bag and close the bag.
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Place a tag or label on the outside of the red bag to indicate the nature of its contents.
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Put the red bag into the used coats container labeled with biohazard symbol. The laundry vendors have their own Bloodborne pathogens procedures on which you will be advised if this practice needs to change.
Remember that where hazards exist, workers and people from outside Zoetis Union City must be informed and provided with the opportunity to apply protective measures against exposure.
RECORD KEEPING
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Hepatitis B Declination Statement - length of employment + 5 years
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Workplace Incident Report / Incident Investigation Report – 3 years
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Hepatitis B Vaccine Compliance Form – length of employment + 5 years
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Medical Records and Exposure Incidents - length of employment + 30 years
REFERENCES/RESOURCES
VIDEOS
eLEARNING
FORMS
DOCUMENTS/LINKS
GLOSSARY
Administrative Controls
Chemical Hygiene, BBP, Biosafety, HazCom
Controls include limiting the length of time an employee is exposed to hazardous atmospheres.
Biohazardous Materials
BBP, Biosafety, ERT
Infectious agents, the products of infectious agents, or the components of infectious agents presenting a risk of injury or illness.
Biosafety Cabinet
BBP, Biosafety
A ventilated cabinet which serves as a primary containment device for operations involving biohazard materials.
Biosafety Cabinet - CLASS III
BBP, Biosafety
The Class III biosafety cabinet is a totally enclosed, negative pressure, ventilated cabinet of gas-tight construction. Operations within the Class III cabinet are conducted through protective gloves. Supply air is drawn into the cabinet through high-efficiency particulate air filters. Exhaust air is filtered by two high efficiency particulate air filters placed in series or by high efficiency particulate air filtration and incineration, and discharged to the outdoor environment without recirculation.
Biosafety Cabinet - Class I
BBP, Biosafety
The Class I biosafety cabinet is an open-fronted negative pressured ventilated cabinet with a minimum inward average face velocity at the work opening of at least 75 feet per minute. The exhaust air from the cabinet is filtered by a HEPA filter and discharged without recirculation.
Biosafety Cabinet - Class II
BBP, Biosafety
The Class II biosafety cabinet is an open-fronted, ventilated cabinet. Exhaust air is filtered with a high efficiency particulate air filter (HEPA). This cabinet provides HEPA-filtered downward airflow within the workspace. Class II Cabinets are further classified as type A, type B1, type B2 and type B3. Class II, type A biosafety cabinets may have positive pressure contaminated internal ducts and may exhaust HEPA-filtered air back into the laboratory. Shall provide a minimum inward average face velocity of 75 feet per minute at the work opening. Class II type B1 cabinets have all biologically contaminated internal ducts or plenums under negative pressure or surrounded by negative pressure ducts or plenums, exhaust HEPA filtered air through external ducts to space outside the laboratory, and have HEPA filtered down flow air composed largely of unrecirculated inflow air. Class II type B2 cabinets (also known as "total exhaust" cabinets) have all biologically contaminated internal ducts or plenums under negative pressure or surrounded by negative pressure ducts or plenums, exhaust HEPA filtered air through external ducts to space outside the laboratory, and have HEPA filtered downflow air drawn from the laboratory or outside air. Class II type B3 cabinets (also known as "convertible" cabinets) have all biologically contaminated internal ducts or plenums under negative pressure or surrounded by negative pressure ducts or plenums, exhaust HEPA filtered air through external ducts to space outside the laboratory, and have HEPA filtered downflow air that is a portion of the mixed downflow and inflow air from a common exhaust plenum.
Biosafety Level
BBP, Biosafety
Biosafety levels consist of laboratory practices and techniques, safety equipment, and a laboratory facility appropriate for the operations performed and the hazard posed by the particular biohazard material. The Centers for Disease Control (CDC) and the National Institute of Health (NIH) define the four biosafety levels in the publication, Biosafety in Microbiological and Biomedical Laboratories, 1988 and revisions, and recommend biosafety levels for particular pathogenic microorganisms.
Biosafety in Microbiological and Biomedical Laboratories (BMBL)
BBP, Biosafety
Biosafety in Microbiological and Biomedical Laboratories, Fifth Edition, CDC and National Institutes for Health, 2007, which is hereby, incorporated by reference for the purpose of establishing biosafety requirements in laboratories.
Biosecurity procedures
BBP, Biosafety
Control measures, such as traffic control, disinfection, and isolation, that are implemented to reduce the risk of transmission of infection into, from, or within an establishment. The purpose of biosecurity measures is to prevent direct or indirect animal-to-animal transmission of zoonotic ATPs, release of pathogens into the environment, and infection of people who may come into contact with animals or areas where animals are housed, or with debris from those areas. The specific biosecurity measures necessary depend on the type of operation conducted by the employer. Typically, no provision for biosecurity other than the use of common sanitation measures is required for incidental removal of animal carcasses or other wastes, unless the activity may result in the introduction of pathogens into areas where animals are kept or housed, or unless the animal is the subject of an applicable alert or disease control order
Blood
BBP, Biosafety, ERT
Human blood, human blood components, and products made from human blood.
Bloodborne Pathogens
BBP, Biosafety, ERT
Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV).
CDC
BBP, Biosafety
United States Centers for Disease Control and Prevention
CDPH
BBP, Biosafety
California Department of Public Health and its predecessor the California Department of Health Services
Case
BBP, Biosafety
Either of the following: (1) A person who has been diagnosed by a health care provider who is lawfully authorized to diagnose, using clinical judgment or laboratory evidence, to have a particular disease or condition. (2) A person who is considered a case of a disease or condition that satisfies the most recent communicable disease surveillance case definitions established by the CDC and published in the Morbidity and Mortality Weekly Report (MMWR) or its supplements.
Clinical Laboratory
BBP, Biosafety
A workplace where diagnostic or other screening procedures are performed on blood or other potentially infectious materials.
Containment
BBP, Biosafety, Chemical Hygiene, HazCom, Radiation
The combination of personal practices, procedures, safety equipment, laboratory design, and engineering features to minimize the exposure of workers to hazardous or potentially hazardous agents.
Contaminated
BBP, Biosafety
The presence or the reasonably anticipated presence of blood or other potentially infectious materials on a surface or in or on an item.
Contaminated Laundry
BBP, Biosafety. ERT
Laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.
Decontamination
BBP, Biosafety
Removal or destruction of infectious agents; removal or neutralization of toxic agents.
Decontamination
BBP, Biosafety, Chemical Hygiene
The removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects.
Decontamination
BBP, Biosafety
The use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use, or disposal. Decontamination includes procedures regulated by Health and Safety Code Section 118275.
Droplet precautions
BBP, Biosafety
Infection control procedures as described in Guideline for Isolation Precautions designed to reduce the risk of transmission of infectious agents through contact of the conjunctivae or the mucous membranes of the nose or mouth of a susceptible person with large-particle droplets (larger than 5 mm in size) containing microorganisms generated from a person who has a clinical diseaseor who is a carrier of the microorganism.
Emergency shower
Chemical Hygiene, BBP, Biosafety, HazCom
A unit that enables a user to have flushing fluid cascading over the entire body.
Emergency situation
BBP, Biosafety, Chemical Hygiene, HazCom, Emergency Response, ERT
Any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant.
Employee exposure
BBP, Biosafety, Chemical Hygiene, HazCom
Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection.
Engineered Sharps Injury Protection
BBP, Biosafety
(1) A physical attribute built into a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, which effectively reduces the risk of an exposure incident by a mechanism such as barrier creation, blunting, encapsulation, withdrawal or other effective mechanisms; or (2) A physical attribute built into any other type of needle device, or into a non-needle sharp, which effectively reduces the risk of an exposure incident.
Engineering Controls
BBP, Biosafety, Chemical Hygiene, HazCom
Controls may include working in fume hoods, enclosures, or modify work processes/equipment to decrease the exposure of hazardous atmospheres.
Engineering Controls
BBP, Biosafety
Controls (e.g., sharps disposal containers, needleless systems and sharps with engineered sharps injury protection) that isolate or remove the bloodborne pathogens hazard from the workplace.
Exposure Incident
BBP, Biosafety, ERT
A specific eye, mouth, other mucous membrane, non- intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.
Exposure or exposed
BBP, Biosafety, Chemical Hygiene, HazCom
