What’s supposed to happen in your school?

By Dorothy Wigmore

Nurses encounter blood and other bodily fluids in their schools, some of which may contain infectious hazards. Bus drivers, custodial staff, security guards, teachers, paraprofessionals, athletic directors and others also face such hazards.

In New Jersey’s Madison Public School District, the “others” include speech therapists, playground monitors, principals, physical/occupational therapists and others who provide first aid. The Paterson Board of Education separates the jobs facing possible exposure into two categories: those where it is assumed every employee doing certain jobs is likely to encounter blood or other potentially infectious materials, referred to as OPIM, and those where some employees may have that exposure, such as Epipen delegates and food service workers.

The differences are found in school districts’ Exposure Control Plan (ECP), required by the New Jersey Bloodborne Pathogens (BBP) standard. Last revised in 2001, the regulation focuses on infectious hazards found in blood, especially the human immunodeficiency (HIV), hepatitis B (HBV) and hepatitis C (HCV) viruses. HBV is the greatest concern because it can survive for a week or more on surfaces, and it is much more infectious than HIV.

Since it’s impossible to know on sight who is infected, the standard asserts that you must assume that all blood is contaminated. The same assumption applies to other bodily fluids contaminated with blood, such as tears, vomit, urine, feces, or saliva, and those fluids where it is hard to see what they contain, all known as OPIM. Needles and other materials (e.g., broken glass) may be contaminated with blood or OPIM.

When covered by a plan, school staff need relevant training, protective gear, and—within hours of encountering blood or other potentially infectious material—a health evaluation.

Does your district have a plan? Are you covered?

The BBP standard first took effect in 1993, yet 25 years later, some districts still don’t have an ECP, while others limit the plan’s coverage.

Recently, the Cinnaminson Education Association discovered that its district didn’t have a plan. A student with special needs was spitting, defecating in the hallway and acting out in other ways. Worried about infections and the time it took cleaning staff to arrive, members went to CEA President Tamara Gross for help. Gross asked her NJEA UniServ field representative for information, leading to a technical assistance request of the New Jersey Work Environment Council (WEC).

“A meeting with the WEC consultant brought attention to the fact we didn’t have an accurate plan in place to deal with the contamination and the clean-up of it afterwards,” she says. “It forced the district to create a plan.”

To develop an ECP, the standard allows districts to decide who is exposed, and, therefore, covered by the plan. “Exposure” is defined as “reasonably anticipated” to come in contact with blood or OPIM via eyes, mucous membranes, or skin breaks (e.g., from cuts, bites, needle sticks).

For accuracy, districts must look at more than job descriptions. What happens when the school nurse is not there, and someone gets injured in after-school wrestling or at football games? Who cleans up when students act out their frustrations by spitting or defecating, or when someone’s colostomy bag becomes loose? When cleaning is outsourced, how many custodians are on the job at any time, and where are they? How do teachers deal with blood in their classroom?

An ECP should cover everyone in a school, says WEC consultant and former art teacher, Allen Barkkume.

“With 120 students a day for 180 days, to think that one of them is not going to bleed in your classroom ignores reality,” Barkkume says. “Every year I had at least a dozen incidents with bleeding students in my classroom or the hallway. At our school, we had almost everyone—teachers, custodians, others—come out to the training every year. It doesn’t take long. Give everybody some gloves, and more if they need it. It’s a no-brainer.”

That’s what the New Jersey Department of Education expects. Its August 2017 letter about school health mandates says, “Schools and daycare facilities are required to provide training and appropriate supplies for all school personnel” to meet the standard.

What should be in an Exposure Control Plan?

When covered by a plan, school staff need relevant training, protective gear, and—within hours of encountering blood or OPIM—a health evaluation. They also must be offered an HBV vaccine, at the employer’s expense and on work time, within 10 days of starting their job.

The HBV vaccine is one of several control measures in a plan. (See the resources sidebar for the state’s model ECP.) Others include:

• Universal precautions to handle all human blood and OPIM as if they are contaminated.

• Methods to contain or remove the hazard without human contact.

• Personal protective equipment (PPE) such as gloves, goggles or a face shield, aprons (when splashes, sprays, splatters, or droplets of potentially infectious materials are likely through the mouth, nose or eyes), and more (e.g., covers for clothing, footwear, head) for extensive contamination.

• Schedules for regular cleaning and disinfecting for contaminated materials, e.g., carpet and surfaces.

• Disposal methods consistent with hazardous waste regulations.

Everyone who’s covered must have training about BBP hazards, the plan, how to remove PPE, cleaning procedures, responsibilities, etc. The employer must provide the PPE, making sure it’s what is needed for the job and that it fits, is readily available, maintained and cleaned properly, and replaced as needed.

The regulation also requires:

• The district to maintain a sharps injury log.

• The plan to be reviewed and updated at least every year, during which technological changes to eliminate or reduce BBP exposure must be considered.

• The district to keep records about training and exposures, recording the latter on the 300 logs.

• The plan to be accessible to all employees.

• The district to provide free, confidential medical evaluation and follow-up for any employee exposed on the job to blood or OPIMs, including blood testing (with consent), post-exposure treatment and counselling and a written report about the incident.

What should local associations do?

Check to see that your school has an ECP. If not, contact your NJEA UniServ field representative and meet with the district and develop one.

Review the ECP. Make sure everyone in the school will get basic training, and those who are expected to clean up have the training, information, time and equipment they need.

For EAs that don’t include cleaning staff, reach out to the union representing them, or the individuals involved, to ensure they have the proper information, training, equipment and time to deal with bloodborne pathogens.

Bring it up at your health and safety committee meeting. Determine how the committee and/or the EA should be involved in the annual plan review and negotiate for that to happen.

Ask NJEA for the best plans in the state or elsewhere. Negotiate changes in your district’s plan to improve it to those “best practices.”

Dorothy Wigmore is a long-time health and safety specialist, trained in occupational hygiene, ergonomics, work organization/stress and education. A former journalist, the Canadian has worked in Canada, the U.S. and Mozambique and been involved in efforts to prevent violence on the job since 1989.

Use the safest cleaning products

Disinfection and cleaning products can be hazards too. Some districts have banned bleach which, for example, can cause and aggravate asthma and can burn skin, and suggest EPA approved disinfectants as alternatives. The San Francisco Department of the Environment offers more protective advice, saying:

“Products must be EPA registered as disinfectants or hard surface sanitizers and contain only the following active ingredients: hydrogen peroxide, citric acid, lactic acid, or caprylic acid. Products must not contain quaternary ammonium compounds or alkylphenol ethoxylates. Concentrated products must be adapted for use in a closed-loop dilution system.” (Learn more)


“PEOSH Bloodborne Pathogens Standard (29 CFR 1910.1030)” and other materials (including a Model bloodborne pathogens exposure control plan) available here.

“Personal Protective Equipment (PPE) Reduces Exposure to Bloodborne Pathogens,” OSHA, available here.

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