References: Department of Environmental Health and Safety
Authority: Occupational Safety and Health Administration (OSHA), 29 CFR (Code of Federal Regulations) 1910.1030; Executive Memorandum No. 88-11, December 12, 1988; Vice President for Business and Fiscal Affairs
Wright Way Policy
Non-occupational Exposure to Bloodborne Pathogens
Policy Number: 6034
References: Department of Environmental Health and Safety
To address the health concerns related to non-occupational exposures to bloodborne pathogens to university students, employees, and volunteers.
a. This policy covers the process and financial responsibilities of university students, employees, volunteers, and Wright State University concerning medical services provided following non-occupational exposures to blood or other potentially infectious material (OPIM).
b. This policy does not cover occupational exposure to blood or OPIM. Procedures for addressing occupational exposure can be found in the University's Exposure Control Plan available from the Department of Environmental Health and Safety.
Bloodborne pathogens - pathogenic microorganisms and viruses that are present in human blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis virus (HBV) and human immunodeficiency virus (HIV).
Exposure - eye, mouth, mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials.
Immediate Health Care Services - may include any of the following:
- Medical counseling and associated services provided immediately following the exposure to document the route of exposure and circumstances related to the incident and provide recommendations for further medical services.
- Blood tests to monitor for potential infectious agents/antibodies per Public Health Service Guidelines, including the costs for testing a source individual.
- Booster immunizations provided immediately following the exposure.
Non-occupational exposure - Exposure to blood or OPIM by university employees, students, or volunteers which occurs while on campus or off campus in an academic or research setting or while providing a service for WSU or in support of the activities of WSU. This category applies to university employees only under the following conditions:
- The employee is in a non-work status and is exposed to blood or OPIM while providing a service for WSU or in support of the activities of WSU.
- The employee is on official work status and becomes exposed to blood or OPIM while conducting activities not normally associated with their job description.
Other potentially infectious material (OPIM) - human blood, human blood components, and products made from human blood; semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; and/or any unfixed tissue or organ (other than intact skin) from a human (living or dead); human immunodeficiency virus (HIV)-containing cell or tissue cultures, organ cultures, and HIV or HBV containing culture medium or other solution; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
Person-in-charge - Any person who is responsible for and/or supervises activities of other people who have non-occupational exposures. This person may be a supervisor, principal investigator, department chair,, director, clinical instructor, or a person in charge of a university sponsored program.
Source Individual - individual, living or dead, whose blood or other potentially infectious materials may be a source of exposure to blood or other potentially infectious material(s). Examples include, but are not limited to, hospital and clinic patients; clients in institutions for the developmentally disabled; trauma victims; clients of drug and alcohol treatment facilities; residents of hospices and nursing homes; human remains; and individuals who donate or sell blood or blood components.
Volunteer - uncompensated individuals who perform work or provide services to WSU, support the activities of WSU, or to gain experience in specific endeavors.
Office of the Provost - Provide a funding account to pay for medical services provided under this policy that are not deemed the responsibility of the exposed individual or off-site clinic or location.
Environmental Health and Safety
- Develop, review, and revise as necessary this policy.
- Manage the reporting process established in this policy.
- Ensure the proper distribution of funds from the account established under this policy to pay for costs over and above the personal insurance coverage of the exposed individual that are the responsibility of Wright State University.
University Units Working in a Volunteer or Didactic Manner with an Off-site Facility (includes the Boonshoft School of Medicine and the College of Nursing and Health)
- For those off-site facilities capable of providing immediate health care services (i.e., hospitals, urgent care facilities) the university unit shall develop and implement contractual agreements with the off-site medical facilities that stipulate the responsibility of the medical facility to provide, at their cost, all immediate health care services in keeping with the current Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis for any university student, employee, or volunteer who may experience a non-occupational exposure to blood or OPIM while performing duties at the off-site medical facility.
- The university unit shall assume financial responsibility, when an off-site medical facility fails to do so contrary to the established contractual agreement, for any immediate health care service provided as a result of their student, volunteer, or employee experiencing a non-occupational exposure to blood or OPIM.
- Ensure anyone serving under their supervision who experiences a non-occupational exposure is provided immediate health care services as described in this policy.
- Ensure a Wright State University Occupational/Non-Occupational Injury/Illness & Incident Report, available from Environmental Health and Safety (EHS, is completed and submitted to EHS following any non-occupational exposure to anyone serving under their supervision.
- In cases when the exposure is a result of a needlestick ensure a BWC Sharps Injury Form Needlestick Report, available from EHS, is completed and submitted to EHS.
- To ensure coverage under this policy the individual shall follow all pre and post exposure procedures, including, but not limited to, the use of universal precautions and all applicable procedures set forth in section 5 of this policy as well as any procedures established by their college or university unit.
- Submit for coverage under their personal health insurance the costs for health care services, not otherwise covered under this policy, following a non-occupational exposure to blood or OPIM.
When a university student, employee, or volunteer experiences a non-occupational exposure as defined in this policy they should immediately wash the injury site with soap and water and report the exposure to the person-in-charge.
Depending on applicability an exposed individual shall accomplish one of the following:
- If exposure occurs at an off-site medical clinic contact infection control, employee health, or emergency services to facilitate an exposure risk assessment and initiate any immediate health care services as deemed appropriate.
- If exposure occurs at an off-site, non-medication type facility or location, or on-campus after hours, report to the nearest emergency room or urgent care facility to facilitate an exposure risk assessment and initiate any immediate health care services as deemed appropriate.
- If exposure occurs on campus during operating hours of Student Health Services (SHS) report to SHS to facilitate an exposure risk assessment and initiate any immediate health care services as deemed appropriate. If health care services are beyond the capabilities of SHS the exposed individual may be referred to another healthcare facility for proper care.
All immediately health care services provided to an exposed individual under this policy will be at not cost to the exposed individual over and above their insurance coverage. Expenses for immediate health care services will be the responsibility of the entity identified under the contractual agreement stipulated in section 5c of this policy. In cases when no contractual agreement has been established between a university unit and an affiliated medical facility the costs will be paid by the university unit. In cases when exposure occurs at a campus facility or at an off-site location where no contractual agreement for the facility to assume financial responsibility is possible (i.e. free clinic) the costs will be paid via the fund established in section 4a of this policy.
Any additional medical services provided immediately following the exposure or recommended as follow up medical services shall be the full financial responsibility of the exposed individual. This may include, but not be limited to:
- Post-exposure prophylaxis.
- Medical counseling provided beyond that experienced immediately following the exposure.
- Blood tests to monitor for potential infectious agents/antibodies beyond that experienced immediately following the exposure.
The person-in-charge, collectively with the exposed individual, shall complete and submit a Wright State University Occupational/Non-Occupational Injury/Illness & Incident Report, and if applicable, a BWC Sharps Injury Form Needlestick Report.
a. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis http://www.cdc.gov/mmwr/pdf/rr/rr5011.pdf