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Bloodborne Pathogen Compliance and Safety


Those in a learning environment are exposed to germs and potentially infectious agents daily. Any bodily fluid carries the risk of disease and puts you in danger of infection, from cleaning up a bloody nose to a child’s vomit, picking up a used tissue left on a desk, or administering first aid. All school staff members need to be familiar with their policies and procedures to prevent bloodborne pathogen exposure.

Bloodborne pathogen compliance is one of two educational facility protocols required for local government, the other being Hazard Communications, originally administered by the Occupational Safety and Health Administration (OSHA). The Texas Department of State Health Services (TDSHS) is the regulatory authority in our state for these protocols, and they have the authority to conduct routine compliance audits.

What Are Bloodborne Pathogens?

Bloodborne pathogens are infectious microorganisms in human blood that can cause disease. Millions of people carry them but are not aware they are. One of the most dangerous traits of a bloodborne pathogen is that symptoms do not always surface immediately. For some, it can take weeks or even months for symptoms to appear. In the meantime, infected people are interacting with staff and students. That’s why it’s vital to prevent exposure in all situations. This includes:

Bacterial pathogens:

  • Staphylococcus (Staph)
  • Streptococcal pharyngitis (Strep)

Viral pathogens:

  • Hepatitis B (HBV)
  • Hepatitis C (HCV)
  • Hepatitis D (HDV)
  • HIV
  • Ebola
  • Zika

Bodily fluids that can carry these pathogens include:

  • Blood
  • Saliva
  • Vomit
  • Mucus
  • Urine
  • Feces
  • Semen or vaginal secretions

These pathogens can spread even if the blood has dried, and even if it’s up to a week old. You should always treat blood and bodily fluids as if they are infected.

Training Requirements

For new employees, training should be comprehensive and should happen before they start work that could expose them to bloodborne pathogens. This should include exposure control, personal protective equipment, and district policy and procedures. Yearly refresher courses on district policy and procedures are required for all staff, even those who have already been trained.

Registered nurses are generally viewed to be qualified to conduct training. Otherwise, safety/health instructors who have special training or who have experience conducting OSHA bloodborne pathogen training can also lead.

Fund members, aside from those with UC coverage only, can use Vector Solutions online training, a value-added benefit through their coverage. Any school can use these resources from TDSHS.

Exposure Prevention

TDSHS has specific guidelines for preventing the spread of bloodborne pathogens in schools. Your district is required to have its own policy statement as well as a written exposure control plan.   

TDSHS requires an annual review of exposure and control procedures to minimize occupational risk from bloodborne pathogens.

One key element in prevention is universal precautions. That means washing hands with soap under running water for at least 20 seconds. It also requires personal protective equipment (PPE) whenever a person comes into contact with another person’s bodily fluids.

PPE includes:

  • Disposable gloves
  • Protective goggles
  • Face shields

Staff should never touch someone else’s blood or clothing containing blood or human tissue without first putting on PPE. It’s also important to know how to safely remove disposable gloves. There is a breakdown in the Vector Solution’s training course. Staff must also wash their hands after disposing of the gloves in a hazardous waste container.

Keep in mind it may not be necessary to touch a person who is bleeding. If the person is conscious, calm, and old enough to follow instructions, staff can give them a sterile gauze or towel and tell them to apply direct pressure on the wound. Other students and staff should be kept away from the area so they don’t come into contact with the blood or bodily fluids. Then, staff should ask for help by phone, intercom, or student messenger.

Bloodborne Pathogen Vaccines

TDSHS requires that employers offer HPV vaccines at no cost to at-risk employees. The district risk manager should determine who is “at risk” by reviewing job descriptions and categorizing employees. All details must be outlined in the exposure control plan. Some districts may decide to offer the vaccine to all employees. But it’s important to know the district only assumes the financial cost for employees with the highest risk.

The HBV vaccine is 85-97% effective in preventing HPV even after an exposure. There are vaccines for certain viruses, including the flu, hepatitis A, and hepatitis B. Currently, there are no vaccines for hepatitis C or HIV. Unfortunately, antibiotics are not effective against viruses.

If you have questions, contact your school nurse or district health official for clarification.

Reporting and Contaminated-Sharps Injuries

Employers are required to keep a log of any injuries or sickness on the job. That means under regulations, employers must also keep a sharps injury log. This should include the type and brand of device involved in the injury, the department or work area where the exposure happened, and what happened. This log should protect the injured employee’s confidentiality.

Example Training: Cleaning Up After Possible Exposure

Here is an example of what may be covered in employee training: cleaning up after possible exposure.

Exposure control plans should instruct teachers and staff to never clean up any bodily fluids and instead contact a custodian, unless trained on the proper protocol and provided the proper PPE.

When cleaning up after an accident with an exposure risk, staff should wear disposable gloves and use paper towels to clean up the fluids with a district and EPA approved disinfectant. All blood must be cleaned up thoroughly before applying the disinfectant. Staff should read the manufacturer’s instructions for the necessary contact time to decontaminate a surface. For HIV and HPV, some instructions require the disinfectant to sit anywhere from 30 seconds to 10 minutes.

If brooms, mops, or dust pans are used, they must also be disinfected or disposed. Try to use disposable equipment when you can. Contaminated materials like gloves and towels should be placed in a leakproof bag labeled “Biohazard,” sealed, and disposed of in a biohazard waste bin. Never throw contaminated items in a regular trashcan.

Any cleanups of sharp items should also be done by a trained employee with appropriate PPE, including puncture proof gloves. Use tweezers to pick up the bigger pieces of broken glass and clean up smaller pieces with a broom and dustpan. Those items must then be disinfected or disposed of in an approved container. All the broken glass or sharps should be put in a sharps container designated for those items.

Any exposed body areas should be thoroughly cleaned with soap and water. If the mouth or eyes are exposed, flush them out repeatedly with large amounts of water after cleaning your hands.

Report the incident immediately to your school nurse or other designated school health official after it’s cleaned up.

Assess Compliance Status

In summary, assess the compliance status of your BBP Program with these questions:

  1. Where can I find a copy of our written program?
  2. When was the last time we provided staff training and who attended?
  3. Do you need to update which staff have access to vaccinations?

Hazardous Chemical Compliance at a Glance

The Texas Hazard Communication Act is the other safety protocol required for schools. Learn how to comply with the law and protect your employees from hazardous chemicals.

Risk Solutions Staff

The TASB risk solutions team includes risk solutions consultants and communications professionals who deliver training, consultations, articles, and resources that help Fund members control losses and their associated costs.

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