This policy is intended to prevent exposure of students, faculty, and staff at CHSU to infectious diseases and injuries during clinical and laboratory activities and is applicable to all individuals using clinical and laboratory space at CHSU.
All CHSU students, faculty, and staff must participate in training in standard precautions to prevent exposure to potentially infectious pathogens and follow-up procedures in the event of accidental contact. This mandatory training occurs annually during the Fall semester.
All new CHSU students, faculty, and staff who may be exposed to potentially hazardous materials are trained in standard precautions and exposure risks during their orientations. Employees are assigned electronic courses during onboarding. Osteopathic Medical students are required to complete compliance modules on an annual basis that includes blood borne pathogens and infectious exposure through online modules. Student orientation is provided at the beginning of their clinical clerkships with respect to their hospital’s or clinic’s written Exposure Control Plan (ECP) required by the Occupational Safety and Health Administration (OSHA) and students must follow the respective institution’s ECP during their clinical clerkship. Pharmacy students are trained by the COP Experiential Education department prior to commencing experiential learning.
CHSU students’ records of exposure incidents and subsequent follow-up information will be kept on file in their college’s Office of Student Affairs. Any faculty or staff exposure incidents will be followed up and filed by the Human Resources Office.
Each college and the Human Resources Office will maintain an internal procedure governing the tracking of training and exposures.
The following guidelines and precautions must be followed:
- Standard Precautions: The term “standard precautions” is an approach to infection control. According to the concept of Standard Precautions, all human blood and certain human body fluids are always treated as if known to be infectious for HIV, HBV, and other blood-borne pathogens. CHSU students are considered healthcare workers, bound by the standards of their clinical education site, when participating in clinical and community experiences. As such, students, faculty and staff are required to abide by the OSHA regulations for healthcare professionals who are considered to be at risk of occupational exposure to blood-borne diseases.
- Faculty are prohibited from engaging in academic activities which might expose students to potentially infectious material without a plan in place for implementation of standard precautions.
- Additional steps to prevent exposure that faculty, staff and students must take:
- Use blunt instruments in laboratory settings as appropriate.
- Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials.
- Take appropriate precautions when handling blood or other potentially infectious materials: use gloves, masks, and gowns if blood or other possibly infectious material exposure is anticipated.
- Set up all equipment in a safe manner to limit exposure.
- Exposure Incident: An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with potentially infectious or hazardous material. Contact can occur via a splash, needle stick, puncture/cut wound from sharp instrument, or human bite. Potentially infectious body fluids include blood, semen, vaginal secretions; pleural, pericardial, synovial, peritoneal, cerebral spinal, amniotic fluid; saliva during dental procedures; any other body fluid visibly contaminated with blood; any unfixed tissue or organ (other than intact skin) from a human (living or dead).
- Associated Expenses: Exposure incidents for students should not be submitted as Workers’ Compensation claims unless the student is employed by CHSU. University policy requires that CHSU students have health insurance. In accordance with this policy, health care expenses associated with an exposure incident are to be billed to the student’s respective insurance carrier for payment. Exposure incidents for CHSU faculty or staff should be reported directly to their supervisor and to Human Resources, at which point any workers’ compensation claims will be discussed and determined.
Procedures
If a student experiences an exposure incident while participating in clinical experiences and/or clinical laboratory activities, it is to be handled as an emergency.
The student is required to:
- Immediately cleanse the wound with soap and water or if contact in the eye(s) or mucus membranes flush with water for several minutes.
- Contact the appropriate CHSU personnel immediately at the CHSU Health, Wellness, and Counseling Services
- Use the QR code for badges/clerkship manual to link to the CHSU Health and Wellness page
- Complete and submit an Exposure Form (to the Office of Student Affairs)
- UCSF PEP Guidelines
- Complete a non-employee incident report and send within 24 hours to the Office of Student Affairs. The form may be submitted electronically.
- If Year 1 or 2 report the exposure incident to the Office of Student Affairs and Instructor of Record.
- If Year 3 or 4 report the exposure incident to the Office of Student Affairs and Instructor of Record, to the Associate Dean of Clinical Affairs/Experiential Education Director and Clinical Preceptor.
- Proceed to the nearest emergency department for immediate evaluation and treatment as needed.
If a faculty or staff member of CHSU experiences an exposure incident, the employee is required to follow protocol set forth in the Injury Illness Prevention Program (IIPP) as follows:
- Employees are to report all injuries to the Office of Human Resources and The Safety Director, as identified in the University IIPP, immediately. Failure to report accidents and injury will be cause for disciplinary action, up to and including termination.
- For non-emergencies, first responders will provide first aid, as necessary, and the injured employee(s) will be directed to the appropriate medical facility. Dial 9-1-1 for emergencies.
- Management will contact the workers’ compensation insurance carrier within twenty-four hours of a work-related injury or illness notification and provide the operator with information about the injury. In the event of an employee’s death or in-patient hospitalization, the company will notify its workers’ compensation carrier within eight (8) hours.
All injuries, regardless of how minor, must be reported.