Under federal regulations, OSHA requires that all employers with employees who may be exposed to bloodborne pathogens implement an exposure control plan. The purpose of this plan is to identify employees at risk of occupational exposure to bloodborne pathogens and implement control measures designed to decrease these risks.

The OSHA standard also requires the plan to contain the following information:

  1. An exposure determination list. This list includes all job classifications where employees have occupational exposure to bloodborne pathogens.

  2. The schedule and method used to implement all provisions of the standard.

  3. The procedure for evaluating exposure incidents and the procedure used to evaluate post exposure incidents.

The plan must be available to all employees and be reviewed on an annual basis. This information will be maintained in the Health Center, the Human Resources Office, and areas where there are employees with occupational exposure to bloodborne pathogens.

This Exposure Control Plan was produced by the Hepatitis B Committee. We gratefully acknowledge Colby College for the information provided in the development of the plan.


These standard definitions, as defined by OSHA, apply at Middlebury College.

Blood: Human blood and blood component.

Bloodborne Pathogens: Microorganisms present in human blood, which may cause disease in humans.

Clinical Laboratory: A workplace where diagnostic and screening procedures are performed on blood or other potentially infectious material.

Contaminated: The presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.

Contaminated Laundry: Laundry which has been soiled by blood or other potentially infectious materials or that may contain sharps.

Contaminated Sharps: Any contaminated object that can penetrate the skin including, but not limited to needles, broken glass, and capillary tubes.

Decontamination: Physical or chemical means of removing or inactivating bloodborne pathogens to the point where they are considered safe for handling, use or disposal.

Engineering Controls: e.g., sharp containers, self-sheathing needles that isolate or remove bloodborne pathogens hazards from the workplace.

Exposure Incident: Specific eye, mouth, other mucus membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that result from the performance of an employee’s duties.

HBV: Hepatitis B Virus

HIV: Human Immunodeficiency Virus

Occupational Exposure: Reasonably anticipated skin, eye and mucus membrane or parenteral contact with bloody or other potentially infectious materials that may result from the performance of an employee’s duties.

Parenteral Exposure: Piercing mucus membranes or the skin barrier through such events as needle sticks, human bites, cuts, or abrasions.

Personal Protective Equipment: Specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes are not considered protective equipment.

Regulated Waste: Liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state in compressed. Items that are caked with dry blood or other potentially infectious materials and are capable of releasing these materials during handling. Contaminated sharps; pathological and microbiological wastes containing blood or other potentially infectious materials.

Sterilize: The use of a physical or chemical procedure to destroy all microbial life including highly resistant endospores.

Work Practice Controls: Controls that reduce the likelihood of exposure by altering the manner in which a task in performed.

Exposure Control Plan: A written established plan designed to eliminate or minimize exposure. This plan shall include: the determination of exposure, the method of post vaccination follow up, communication of hazards with employees and record keeping. This information is available to any employee upon request, and will be reviewed/revised annually.

Exposure Determination: List of all job classifications which have occupational exposure.

Exposure Determination

All job descriptions at Middlebury College with exposure risk have been classified according to risk of occupational exposure to bloodborne pathogens. These classifications are defined as follows:

CATEGORY A: This category includes all employees who have routine exposure to bloodborne pathogens, primarily Health center staff, training room staff, laundry operators, ski patrol, and security personnel.

CATEGORY B: This category includes all employees who do not routinely have exposure to bloodborne pathogens, but may, on occasion, perform tasks which involve potential exposure, primarily crew custodians, coaches, ERT and assistant coaches.

CATEGORY C: This category includes all employees who do not have any occupational exposure to bloodborne pathogens, primarily faculty, administrators and support staff not identified in Category A or B.

Middlebury College has defined these classifications to include the various tasks within these categories where occupational exposure might occur.

These tasks have been grouped as follows:

  1. No occupational exposure
  2. Handling of contaminated linen/clothing.
  3. Handling of contaminated sharps and venous access.
  4. Handling of contaminated surgical instruments.
  5. Cleaning of surfaces/equipment contaminated with body fluids.
  6. Insertion of tubes or other equipment into body surfaces.
  7. Handling/exposure of body fluids.
  8. Wound care/dressing changes.
  9. Responding to emergency situations.
  10. Handling of contaminated trash.

Middlebury College has determined that any Category A or Category B position will be treated as a Category A position for the purposes of employee training and identification of employees eligible for the administration of Hepatitis B vaccine. The only exception would be limited to persons who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents, generally at the location where the incident occurred (i.e. Coaches, Assistant Coaches and Night Watch). Based on the low risk of exposure for these first aid providers, OSHA believes that post-exposure prophylaxis, including Hepatitis B vaccination within 24 hours of possible exposure, minimizes the risk to employees. All other requirements of the standard, including reports and training, must be met.

Job Classification with Occupational Exposure

The following chart lists potential exposures and job classifications by department:

Health Services
Admin Dir’r Health Center, 1-9/A
Medical Director, 1-9/A
Staff Nurse, 1-9/A
Nurse Practitioner, 1-9/A
Asst Head Nurse, 1-9/A
Receptionists, 8/B

Biology and Chemistry
Faculty, 2,3,4,5,6/B
Teaching Assistant, 2,3,4,5,6/B

Facilities Management
Night Watch, 7,8/B
Crew Custodian (Floater), 1,4,9/B
Custodian for Health Center, 1,4,9/B
Issue Counter Attendant, 1/B
Laundry Operator, 1/A
Landscaping, 2/B
Custodian, 1,4,9/B
Supervisor Custodian, 1,4,9/B
Maintenance Plumber, 4/B
Team Leader, 1,4,9/B
Recycle Center, 2,6,9/B

Athletics and Physical Education
Coach/Faculty, 7,8/B
Assistant Coach, 7,8/B
Equipment Manager, 1/A
Asst Equip Manager I, 1/A
Asst Equip Manager II, 1/A
Coord of Sports Medicine, 1-9/A
Physical Therapist, 1-9/A
Head Athletic Trainer, 1-9/A
Athletic Trainer, 1-9/A
Registered Nurse, 1-9/A
Student Trainers, 1-9/A

Public Safety
Director of Public Safety, 7,8/A
P.S. Officer, 7,8/A
Lieutenant, 7,8/A
Sergeant, 7,8/A

Snow Bowl
Ski Patrol Director, 4,6,7,8/A
Professional Ski Patrol, 4,6,7,8/A
Lodge Caretaker/Janitor, 1,4,9/B
Student Ski Patrol, 4,6,7,8/A

Housekeeper, 1,4,9/B

Residential Life
Residence Hall Advisor, 7,8/B

Emergency Response Team, 7,8/B

Cooks and Kitchen staff, 2,4,7/B

Methods of Compliance

To decrease occupational risk to bloodborne pathogens the college has developed the following system to isolate contaminated needles in a safe fashion:

All needle disposal units at Middlebury College are made of rigid plastic which prevent needles from piercing through the container. These units are also leak proof. Disposal units are strategically placed to allow for disposal as quickly as possible.

These units are inspected daily and replaced when full. This further reduces the potential for accidental exposure, due to overfill. Eyewash stations shall be installed at the Health Center at all hand washing sinks.

These are in use where occupational exposure to pathogens might occur. All microbiological and parasitic specimens are processed using these cabinets. Bio-Safety cabinets are also used when specimens are separated and processed. These cabinets are certified every six (6) months. Documentation is maintained in the office of the Administrative Director of the Natural Sciences Division.

The following procedures must be followed by all
employees with exposure to bloodborne pathogens. Employees shall wash their hands
immediately or as soon as feasible after removal of gloves or other personal protective


Handwashing is the single most important means of preventing the spread of infection. It is also an important measure to decrease occupational exposure to bloodborne pathogens. Gloves are not a substitute for hand washing.

  1. Use warm running water.
  2. Use mild liquid soap.
  3. Friction is the most important part of the hand washing procedure. Careful washing between fingers is essential.
  4. Hands are thoroughly rinsed while they are held downward.
  5. Dry thoroughly with paper towel.
  6. Turn water faucet off with paper towel. (This prevents recontamination of the hands.)

Hands should be washed:

  • After touching any patient
  • After touching any patient secretions, or any potentially infectious material.
  • Before leaving any isolation room.
  • Before performing invasive procedures.
  • After performing personal bodily functions.
  • After performing any job where a person comes in contact with any potentially contaminated material.
  • Following any contact of body areas with blood or any other infectious materials, employees should wash their hands and any other exposed skin with soap and water as soon as possible, and flush exposed mucous membranes with water.

In the event that a sink is not available, hands may be washed with an antiseptic solution. If this method is used, hands must be washed with soap and water as soon as feasible.

Other Important Infection Control Measure

  1. Eating, drinking, smoking, applying cosmetics, lip balm and handling contact lenses are prohibited in work areas where there is reasonable likelihood of occupational exposure to infectious agents.
  2. Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets or on counter tops or bench tops where bloodborne or other potentially infectious materials are present.
  3. All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing. Employees shall be trained in these techniques during the orientation period.
  4. Contaminated needles and other contaminated sharps are not bent, recapped or removed unless: 1) There is no feasible alternative; 2) The action is required by a specific medical procedure; 3) In the two situations above, the recapping or needle removal is accomplished through the use of a medical device or a one-handed technique.
  5. Contaminated sharps are places in an appropriate container immediately or as soon as possible after use.

The use of PPE may decrease occupational risk to bloodborne pathogens. PPE is provided to employees at no cost and must be accessible in all areas where occupational exposure is possible.


Gloves must be used when:

  1. There is a likelihood of contact with blood or other body fluids
  2. During venous access procedures and when giving injections.
  3. When there is contact with mucus membranes and nonintact skin.
  4. When contaminated items/surfaces are handled.

  5. Disposable gloves must be discarded when contaminated and may not be rewashed.

  6. BVM and other barrier devices use when performing CPR must be discarded.

Safe Needle Devices

Must meet OSHA’s definition shall be employed in the Parton Health Center, Sports Medicine Office or wherever required under VOSHA regulations.

Utility Gloves

Must be used to perform housekeeping activities when the possibility of occupational exposure exists. These gloves may be decontaminated, but must be disposed of when cracked or no
longer intact. To decontaminate, the gloves will be washed with bleach.

Masks, Eyewear, and Face Shields

Face and eye protection must be used when there is potential for splashing, spraying, spattering of blood or other potentially infectious materials into the eyes or mouth. Glasses must have rigid side shields in order to be considered PPE. When eyewear is worn as PPE, a mask must be used to protect the nose and mouth. If face shields are selected, the shield must be worn with a mask.

Engineering Controls: Potentially contaminated broken glass shall be picked up using mechanical means such as a dustpan, brush, tongs, and/or forceps.

Gowns, Aprons, or Lab Coats

All gowns or aprons selected as PPE must do the following:

  1. Adequately cover clothes.
  2. Prevent blood or other fluid from reaching clothes or skin.
  3. Any garment penetrated by blood or other infectious materials are removed immediately or as soon as feasible.

If lab coats are used as PPE, these must be:

  1. Laundered by the College laundry.
  2. Be adequate to the task to prevent contamination of clothes or skin.
  3. If clothing becomes contaminated while on duty, the College shall launder this clothing free of charge to the employee.

All employees shall be trained in the use of PPE at the time of employment

In the event that CPR must be performed on the patient, the employee shall use a mechanical device designed to protect the employee from bodily fluid exposure.

All personnel who respond to disturbances shall be trained in appropriate measures designed to decrease injuries and minimize exposure to bloodborne pathogens. If the employee sustains a human bite during this time, this shall be considered a percutaneous exposure and all follow-up measures for exposure shall be instituted.

Biohazard labels and signs are used by Middlebury College to communicate hazards to employees. The biohazard label includes the universal biohazard symbol and is fluorescent orange or orange-red with lettering or symbols in a contrasting color. They are either an integral part of the container or located as close to the hazard as possible.

Labels shall be affixed to:

  1. Containers of regulated waste.
  2. Refrigerators and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials except for:

  3. Red bags or red containers

  4. Containers of blood, blood components, or blood products that are labeled as to their contents and have been released for transfusion.
  5. Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal.
  6. Regulated waste that has been decontaminated.
  7. Laundry bags.

  8. Labels required for contaminated equipment shall state which
    portions of the equipment remain contaminated.

Signs shall be posted at the entrance of work areas where there is potential exposure to infectious agents. Signs shall be fluorescent orange-red with letters and symbols in contrasting colors. The signs shall contain the following information:

  • Name of the infectious agent
  • Special requirements for entering the area
  • Name, phone number of the responsible person

Hazard Communication (BBP) Training for employees shall take place the time hiring and annually thereafter.

Middlebury College strives to provide a work environment which is maintained clean and as free from potential exposure as possible. All agents used to decontaminate work area are EPA approved and meet standards for deactivating the Hepatitis B and HIV virus.

A detailed schedule for cleaning and decontamination is based upon the location within the facility, the degree of contamination present and the nature of tasks being performed in each area. This schedule is maintained by the Assistant Director, Facilities Management for Custodial Services and is reviewed annually.

The following tasks may be performed by some employees at Middlebury College. All employees shall be trained to perform the tasks in such a way to decrease occupational exposure to bloodborne pathogens.

Work Surfaces

To prevent exposure of the employee to blood or other potentially infectious material remaining on a work surface from a previous procedure, all work surfaces must be decontaminated after completion of each procedure, when they are overtly contaminated during a procedure, and at the end of a work shift. When procedures are performed continually throughout a shift, the work area should be decontaminated after each set of tasks is completed. The work area should be decontaminated if an employee leaves the area so that it does not present a source of contamination to other workers. Work surfaces in patient care areas do not need to be cleaned after each procedure unless that procedure results in the contamination of the area.


All equipment shall be decontaminated immediately if contamination has occurred. Employees who perform this function shall be trained in the methods appropriate to the procedure.

Regulated waste must be properly contained and disposed of so as not to become a means of transmission of disease to workers.

What is Regulated Waste?

Regulated waste is defined as any waste capable of transmitting bloodborne pathogens.

The following wastes are determined to be regulated waste:

  1. Liquid or semi-liquid blood or other potentially infectious material.
  2. Items contaminated with blood or other potentially infectious materials and which would release these substances in a liquid or semi-liquid state if compressed.
  3. Items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling.
  4. Contaminated sharps.
  5. Pathological and microbiological wastes containing blood or other infectious material.

All regulated waste shall be bagged in sealed red bags at the Health Center and properly disposed.

Regulated waste shall be handled using protective equipment. Any container used to transport this waste shall be marked with the biohazard symbol. These containers shall be closeable and leak proof and on the sides and bottom as well as puncture resistant.

A secondary container must be used in situations where the outside of the first container becomes contaminated.

Biomedical Waste

Middlebury College recognizes that biomedical waste may also contain blood and other potentially infectious materials and follows the same procedure for handling, storing, and transporting this waste as for regulated waste.

Included in this category are:

  • Sharps
  • Outpatient Waste
  • Emergency Accident Waste

Responsibility for managing the regulated waste program rests primarily with the department that generated the waste. Regulated waste from the Health Center is collected and transported to an appropriate facility by an outside contractor (Stericycle).
Regulated waste from custodial cleanup should be brought to the Health Center for disposal.

Blood Spills

Blood spills are of extreme concern for transmission of bloodborne pathogens. The following procedure must be followed by all employees who remove or disinfect a blood or bodily fluid spill:

  1. Gloves must be worn for the cleaning of any body fluid spills. Vinyl aprons must be worn for a large spill.

  2. For small body fluid spills in rooms, corridors, etc., visible material should be removed and the area disinfected with a College approved disinfectant or a solution of bleach (1:10) dilution.

  3. For large body fluid spills in the nonpatient care areas: The contaminated area should be completely covered with paper towels and flooded with one of the above cleaning agents. Allow contact time (minimum of ten minutes). Remove soiled paper towels and dispose of in a red bag for incineration. Wet mop area with clean solution.

  4. Large body fluid spills in patient care areas: Spills should be wiped up as soon as possible with paper towels, and the towels discarded in a red bag for incineration. Final clean up of the area should include disinfection of the contaminated surfaces using a solution of bleach (1:10), or hospital approved disinfectant providing for a contact time of at least 10 minutes to complete the disinfection process.

  5. For body fluids containing glass: glass is removed by sweeping with a counter brush and dust pan. Body fluid is then removed following proper procedure as stated in this policy (Procedures 1-4). Equipment used to clean a body fluid is then disinfected using a solution of bleach (1:10), or an approved disinfectant. All glass needs to be disposed of in a manner to prevent exposure to another employee.

  6. Dispose of protective equipment. Wash hands.


Contaminated laundry is defined as any laundry that may contain blood or other potentially infectious material. The following guidelines have been designed to decrease occupational exposure by means of contaminated linen:

  1. Linen shall not be sorted or rinsed in patient care areas.
  2. All personnel shall use protective equipment when handling all
    contaminated linen.
  3. Only laundry bags that prevent soak through or leakage of fluid shall be
    used to contain soiled or contaminated laundry.
  4. All laundry workers shall be trained in the following areas:
  5. Proper method of handling contaminated linen.
  6. Method of selecting protective equipment.
  7. Handling of contaminated sharps.

Standard sharps containers shall be located in the laundry for disposal of all sharps found in contaminated linen. The director of the appropriate department will be notified of any sharps found in contaminated linens for the purpose of incident review and staff education.

Hepatitis B Vaccination

Middlebury College provides the Hepatitis B Vaccine free of charge to all employees who have the potential for occupational exposure during the course of performing their duties. All new employees who are eligible for the vaccine are trained on the provisions of this standard and will be offered the vaccine within ten (10) days of employment.

Middlebury College does not offer the vaccine to new employees who have previously received the vaccine series.

Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.

All current employees with occupational exposure have been identified and will be offered the vaccine prior to December 15, 1992.

All employees who choose to receive the Hepatitis B vaccine must sign an informed consent explaining the benefits derived from the vaccine. Any employee who declines the Hepatitis B vaccine must sign the declination statement at the bottom of the form. At this time the employee will be counseled as to the risks of refusal. If at any time the employee decides to be vaccinated, the vaccine will be administered at no cost. All employees who refuse vaccination will be re-contacted annually and offered vaccination.

Administration of the Vaccine

The Hepatitis B Vaccine will be administered according to the United States Public Health Standards. If in the future these standards require routine booster doses, these shall be offered to all employees with occupational exposure as required by the guidelines. Under current health guidelines, routine post vaccination testing is not required although it is recommended. Employees receiving the Hepatitis B vaccine may have post vaccination testing at the College’s expense.

Record Keeping

Employees and the College shall receive a written opinion from the evaluating health care provider on their vaccination status. A copy of the vaccination consent/declination form and dates of training and vaccination will be kept in the employee’s personnel file.

Exposure Incident

An exposure incident is defined as “specific eye, mouth, other mucus membrane, nonintact skin, or parenteral contact with blood or other potentially infectious materials that result from the performance of an employee’s duties.”

The following steps are to be taken after each exposure incident:

  1. Employee will be administered first aid and seek immediate medical care.
  2. Each incident is to be reported to the supervisor immediately.
  3. The supervisor and the employee will complete an Incident Report as soon possible after the exposure incident.
  4. Each incident is to be evaluated by a licensed health care professional. Once it has been determined that an exposure has occurred, the employee’s personal physician will determine the necessary follow up.We recommend follow up at Porter Hospital Emergency Department.
  5. Identification of source individual, if possible; if indicated, and only when informed consent is obtained, test sources individual’s blood to determine HIV infectivity (this may require consulting with the patient’s attending physician), also, Hepatitis B (surface) antigen, and Hepatitis C antibody.
    The HIV test results will be reported to the ordering physician; the specific results can not be released to the employee unless informed consent is obtained from the source individual. At that time, the employee should be made aware of any applicable laws and regulations concerning confidentiality and disclosure of the identity and infectious status of the
    source individual.
  6. When appropriate, the exposed employee’s blood will be tested for the Hepatitis B and C virus and for the HIV virus. The employee’s health care provider will provide the test results to the exposed employee and provide counseling as medically indicated, including referral to an infectious disease specialist.

Post-Exposure Vaccination and Follow Up

A confidential post exposure medical follow up is performed after each exposure incident. This follow up is provided under the direction of a licensed health care professional.

All employees who have an exposure as previously defined must complete an incident report. This report must be evaluated and signed by the employee’s supervisor. If indicated, the employee will receive further training to correct any problems detected through the incident. The incident report shall be forwarded to the Human Resources Office.

In order to perform the appropriate follow up; the health care professional responsible for the follow up shall be provided with the following information:

  • A copy of the standard.
  • A description of the employee’s duties as they relate to the incident.
  • Documentation of the route of exposure and circumstance under which the exposure occurred.
  • Results of source individuals blood testing, if available.
  • Medical records relevant to the treatment of the employee, including vaccination status.

The employer and employee are provided with a written post-exposure evaluation opinion within fifteen (15) days after the completion of the evaluation. This documentation will include the results of the medical evaluation and any medical conditions which may arise from the exposure that may require further treatment. A copy of this report will be kept in the employee’s medical record.

All needle stick and other exposure incidents that result in medical treatment and follow up shall be documented of the OSHA 200 log. All identifying information pertaining to bloodborne pathogens are removed prior to granting access to the records. Retesting for HIV at the time of the incident, 2 months and 6 months will be recommended.

Medical Records

The Human Resources Office will maintain confidential medical records on all employees with occupational exposure for the duration of their employment and an additional thirty years. All employee medical records are maintained as confidential records and as such will not be disclosed without written consent unless required by law. This record will include:

  1. The name and social security number of the employee.
  2. All information pertinent to Hepatitis B status and vaccination.
  3. A copy of all results of examinations, medical testing, and follow up.
  4. The employer’s copy of the health care professional’s written opinion.
  5. A copy of the information provided to the professional.

Employee Training

Specific information and training about occupational hazards and required protective measures will be provided to all employees with occupational exposure. All current employees with occupational exposure will be provided with this training by November 20, 1992. New employees with occupational exposure will receive training prior to being placed in positions where occupational exposure may occur. Retraining on an annual basis will be required. Provisions will be made to provide training by a qualified trainer whenever a change in an employee’s responsibilities, procedures, or work situation is such that an occupational exposure risk is affected.

Training will be provided by an individual(s) who is knowledgeable in the subject matter (i.e., infection control) at no cost to the employee, during work hours, and at a location reasonably accessible to the employee. The training will be appropriate in content, language, and vocabulary to the education, literacy, and language background of the employee. The training will include:

  1. An accessible copy of the regulatory text of the standard.
  2. A general explanation of the epidemiology and symptoms of the bloodborne pathogens.
  3. An explanation of the modes of transmission of bloodborne pathogens.
  4. An explanation of the appropriate methods of recognizing risks and other potentially infectious materials.
  5. An explanation of the use and limitation of methods that will prevent or reduce exposure including appropriate engineering control, work practices, and personal protective equipment.
  6. Information of the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment.
  7. An explanation of the basis for selection of personal protective equipment.
  8. Information on the Hepatitis B vaccine including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge.
  9. Information on the appropriate action to take and the person to contact in an emergency involving blood or other potentially infectious materials.
  10. An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and medical follow up that will be made available.
  11. Information on the post exposure evaluation and follow up that the employer is required to provide for the employee following an exposure incident.
  12. An explanation of the signs and labels and/or color-coding used to identify hazards.
  13. An opportunity for interactive questions and answers with person conducting the training.

Written training records will be kept in the Human Resources Office for three (3) years. These records will include:

  • The dates of the training sessions.
  • The contents or summary of the training.
  • The names and qualifications of the person conducting the training sessions.