Exposure Control Plan

1. Purpose and policy

LabLatch Logistics is committed to protecting every courier from occupational exposure to blood and other potentially infectious materials (OPIM). This plan puts the requirements of the OSHA Bloodborne Pathogens Standard into practice for specimen transport.

All blood and body fluids are treated as potentially infectious (universal precautions). Every courier must read this plan before their first run and follow it on every run.

29 CFR 1910.1030(c)(1)

2. Plan administrator

The plan administrator keeps this plan current, provides training and PPE, and manages exposure follow-up.

Couriers can request a copy of this plan at any time and receive it within 15 working days.

3. Exposure determination

Job classification with occupational exposure: Medical courier. Every courier in this role can reasonably be expected to contact blood or OPIM, even though specimens arrive packaged.

Tasks and procedures where exposure can occur:

• Receiving, carrying and handing off packaged diagnostic specimens
• Handling a package that is leaking, cracked or damaged
• Cleaning up a spill in a vehicle, cooler or facility
• Repackaging specimens when a client's packaging fails
• Cleaning and disinfecting coolers, bins and the cargo area
• Handling broken tubes, glass or sharps

How much exposure a task carries depends on each client's specimens and packaging. That's documented per contract in the contract risk profiles.

29 CFR 1910.1030(c)(2)

4. Engineering and work practice controls

• Accept only specimens in leakproof triple packaging (primary container, leakproof secondary with absorbent, rigid outer), labeled UN3373 for diagnostic specimens.
• Carry specimens upright in a sealed, lockable container that is secured in the vehicle and separated from the driver's area.
• No eating, drinking, smoking, applying cosmetics or handling contact lenses while handling specimens or in the cargo area.
• Never open a specimen package. Never pick up broken glass by hand; use tongs, a scoop or cardboard.
• Wash hands with soap and water after removing gloves and after any handling. Use hand sanitizer only until a sink is available.
• Keep food and drinks out of coolers used for specimens.
• Controls are reviewed at least once a year and whenever tasks or equipment change.

29 CFR 1910.1030(d)(2)

5. Personal protective equipment

LabLatch provides all PPE at no cost to couriers, in the right sizes, and replaces it when used or damaged.

Remove PPE before leaving the work area, gloves last, peeling them inside out. Dispose of it as regulated waste if contaminated. Contract risk profiles may require more PPE for specific tasks.

29 CFR 1910.1030(d)(3)

6. Housekeeping and spill cleanup

Coolers, bins and the cargo area are cleaned and disinfected at the end of every shift and immediately after any contamination.

Spill procedure:

1. Stop. Keep other people away.
2. Put on two pairs of gloves and eye protection. Add an apron for a large spill.
3. Remove broken glass or sharps with tongs or a scoop into a sharps container.
4. Cover the spill with absorbent from the spill kit, working from the edges in.
5. Apply an EPA-registered hospital disinfectant, or 1 part household bleach to 10 parts water mixed that day. Leave it wet for the label's contact time (at least 10 minutes for bleach).
6. Wipe up, bag everything as biohazard waste, and disinfect the area again.
7. Remove PPE, then wash hands with soap and water.
8. Report the spill to the plan administrator.

Never mix bleach with ammonia or other cleaners. Open vehicle windows while cleaning.

29 CFR 1910.1030(d)(4)

7. Regulated waste

• Contaminated cleanup materials and PPE go in closable, leakproof red bags or containers marked with the biohazard label.
• Broken tubes and sharps go in a puncture-resistant, labeled sharps container.
• Regulated waste is disposed of according to Florida rules for biomedical waste, through the client facility or an approved disposal service [DISPOSAL ARRANGEMENT].

29 CFR 1910.1030(d)(4)(iii)

8. Hepatitis B vaccination

LabLatch offers the hepatitis B vaccine series at no cost to every courier within 10 working days of their first assignment, unless the courier has already been vaccinated, testing shows immunity, or the vaccine is medically inappropriate.

A courier may decline by signing the OSHA declination statement. A courier who declines can change their mind and receive the vaccine later at no cost.

Vaccination provider: [CLINIC / PHARMACY]

29 CFR 1910.1030(f)(2) · Appendix A

9. Post-exposure evaluation and follow-up

An exposure incident is contact of the eyes, mouth, other mucous membranes, broken skin, or a skin puncture with blood or OPIM.

1. Right away: wash the area with soap and water, or flush eyes, nose or mouth with water for 15 minutes.
2. Report to the plan administrator immediately, with the job number and specimen ID.
3. Get evaluated the same day at [URGENT CARE / OCCUPATIONAL HEALTH CLINIC] or the nearest ER. Preventive treatment for HIV works best when started within hours.
4. LabLatch provides the confidential medical evaluation and follow-up at no cost to the courier, including testing, preventive treatment when recommended, and counseling.
5. The client facility is asked to help identify and, where the law allows, test the source specimen.
6. The courier receives a copy of the healthcare provider's written opinion within 15 days.
7. The incident is reviewed to find what failed and how to prevent it.

29 CFR 1910.1030(f)(3)–(f)(6)

10. Labels and signs

Containers of regulated waste, and coolers or bins used to carry potentially infectious materials, carry the fluorescent orange or orange-red biohazard label. Diagnostic specimen packages carry the UN3373 "Biological Substance, Category B" mark.

29 CFR 1910.1030(g)(1)

11. Training

Every courier is trained before their first assignment and at least once a year after that, during paid time and at no cost. Training covers:

• The OSHA standard and where to get a copy, and this plan
• Bloodborne diseases, their symptoms and how they spread
• Tasks that can cause exposure, and the controls and PPE for each
• Hepatitis B vaccine: safety, benefits, and that it's free
• What to do in a spill or exposure, and the follow-up available
• Labels, signs and color coding
• A chance to ask questions of the trainer

29 CFR 1910.1030(g)(2)

12. Recordkeeping

Medical records are kept confidential and separate from other files, and are shared only with the courier's written consent or as the law requires.

29 CFR 1910.1030(h)

13. Annual review

This plan is reviewed and updated at least once a year, and whenever a new contract, task or procedure changes exposure. Each review considers safer equipment and gets input from the couriers doing the work.