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Location: School of Optometry, Minor Hall
Date Revised: September 2015
Associate Dean of Clinic Affairs: Christina Wilmer, O.D., F.A.A.O.
Clinic Chief: Carl H. Jacobsen, O.D., F.A.A.O.
Department Safety Coordinator:  Cliff Lobberegt


Some procedures performed in the School of Optometry’s Clinic and other Research Units (hereafter “Unit”) could cause exposure to blood-borne pathogens. The purpose of this Exposure Control Plan is to describe how to eliminate or minimize the danger of exposure to human blood or other potentially infectious materials, in compliance with the California OSHA Blood-borne Pathogens Standard (8 CCR § 5193) and the departmental Injury and Illness Prevention Program (IIPP).

Standard Precautions: It is the policy of the University of California, Berkeley and the School of Optometry to ensure practice of Universal Precautions to reduce exposure to infectious agents. Universal Precautions are methods of infection control in which all human blood, tissue and certain body fluids are treated as if infectious.


The Associate Dean of Clinic Affairs, the Clinic Chief and the department Safety Coordinator have identified positions and procedures in the Clinic and Research Units, which present the possibility of occupational exposure to human blood or other potentially infectious materials. This determination is based on the risk of potential exposure to blood-borne pathogens in the course of performing assigned job duties. Self-inspection for these risks is also ongoing under the IIPP.

  1. Materials
    The following materials encountered in the procedures performed in the Clinic Unit and other Research Units may cause exposure to blood-borne pathogens:
    • Human blood, blood products, components, or cells
    • Any body fluid visibly contaminated with blood, all body fluids where it is difficult to differentiate between fluids
    • Any unfixed human tissue or organ (other than intact skin)

    NOTE: OSHA does not consider individuals coming in contact with tears, unless the tears contain visible blood, to have exposure to blood-borne pathogens.

  2. Job Classifications at Risk

    Below are listed the job classifications, tasks and procedures where all employees may handle human blood and other potentially infectious materials which may result in possible exposure to blood-borne pathogens:

  3. Ophthalmologist(s)
    The tasks and procedures, which place an ophthalmologist at, risk for exposure to blood-borne pathogens:
    • Injections
    • Handling contaminated sharps or other contaminated waste
    • Cleaning up spills of human blood or other body fluids
    • Exposure to open wounds
    • Minor eye trauma including lacerations and abrasions
    • Minor procedures limited to removal of small masses from eyelids and ocular tissue
    • Laser use – Argon, YAG, Excimer, SLT
  4. Optometrists (Clinical Faculty)
    The tasks and procedures which place an clinical faculty member at risk for exposure to blood-borne pathogens:
    • Handling contaminated sharps or other contaminated waste
    • Cleaning up spills of human blood or other body fluids
    • Exposure to open wounds
    • Assisting in treatment of minor eye trauma including lacerations and abrasions
    • Assisting in minor procedures limited to removal of small masses from eyelids and ocular tissue
  5. Researchers (PI’s and their staff)
    The HIV, HBV, or HCV Research Laboratory must meet the requirements specified in a separate Special Pathogens ECP outlines the requirements for exposure determination, engineering and work practice controls, containment equipment controls, facility design controls, and employee training. 


The Blood-borne Pathogens Standard will be implemented in the Unit by the following methods and schedule:

Written Exposure Control Plan
This Exposure Control Plan will be available to all affected employees. It will be reviewed and revised annually, or whenever any significant changes in procedure or personnel occur.

Work Practice Controls 
The following engineering and work practice controls are employed in our school to minimize exposure to blood-borne pathogens.

Proper hand washing represents one of the most effective means of preventing the transmission of disease. Unit personnel are to thoroughly wash their hands with soap and water immediately before and after each patient /tissue encounter. Each examination and procedure room is equipped with a sink, soap and disposable paper towels. Unit personnel are to wash their hands frequently while working with biohazardous- agents, immediately after removing gloves, and immediately upon any contact with blood or other potentially infectious material. Fingernails should be of reasonable length and clean. Hands should be frequently inspected for cuts, abrasions, or breaks in the skin. If an open wound or weeping lesion is present on the patient, or on the hands of the practitioner/researcher, gloves must be worn.

Eating, drinking, smoking, applying cosmetics or lip balm are prohibited in examination and procedure rooms. Do not place objects (pen, pencil, pipette, pins) into the mouth.
Food and drink brought to the Unit for private consumption must not be placed in refrigerators, freezers, shelves, cabinets, bench tops, ovens or microwaves where blood stained waste or other potentially infectious materials are stored or may be present.

Engineering Controls
Used needles and other sharps are not sheared, bent, broken, recapped, or reheated by hand. Used needles are not removed from disposable syringes. The OSHA standard (8/99) requires that “needle-free” or “engineered” needles and sharp systems be identified and purchased (unless no such systems are available in the marketplace). “Engineered” sharps are those specifically designed with physical controls to prevent exposures. If engineered controls are not used in a specific work area that may expose employees to human blood-borne pathogens, the reason will be documented. Contaminated sharps are to be placed immediately in a puncture-resistant and labeled “sharps container”. A sharps container is located at each Unit’s procedure room.

Engineering controls are examined and maintained on a regular schedule and at least annually to ensure their effectiveness. A list of equipment and the maintenance schedule for each piece is listed below:

Equipment Schedule

Sharps Container
Daily or emptied as needed

Infectious waste disposal receptacle
Daily or emptied as needed

The Unit Chief/PI has determined that the following procedures are appropriate cleaning and decontamination methods for use in this Unit to minimize exposure to infectious material. Standard Precautions dictate using appropriate disinfecting or disposal techniques for all items potentially contaminated with human blood or other infectious materials. These procedures have been in practice since July 1993.

Procedure Rooms
The procedure room is maintained in a clean and sanitary condition. Counter tops, examination chair, research equipment and instrument carts are cleaned with an OSHA approved disinfectant at the conclusion of a procedure, at the end of the day, and after any spill.

Infectious Waste
Infectious waste is handled according to Medical Waste Guidelines, which comply with state law, and University waste disposal and removal guidelines. Infectious waste generated by each Unit is disposed of in an appropriate waste receptacle located in the Unit procedure room (closeable, leak proof container lined with red biohazard waste receptacle liner).

Personal Protective Equipment 
Personal protective equipment (PPE) and clothing appropriate to the activity/procedure is used in each Unit to minimize or eliminate exposure to blood-borne pathogens. All PPE must be inspected, cleaned, or replaced, as needed, in order to maintain effectiveness; this will be done at no cost to Unit personnel.

Unit personnel wear gloves, lab coat, gowns, and appropriate face protection whenever handling human blood, fluids or tissue.

Disposable gloves are readily available for use by Unit personnel. Unit examination and procedure rooms are equipped with disposable latex gloves. All personnel are instructed as to the proper use of gloves including:

  • Gloves are not a substitute for hand washing.
  • Gloves are for single use only and must be discarded after each patient encounter in an appropriate waste receptacle.
  • Hands are to be washed thoroughly after gloves are removed.
  • Gloves are to be worn when it can be reasonably anticipated that the hand may have contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin when handling or touching contaminated items or surfaces. If an open wound or weeping lesion is present on the patient or on the hands of the practitioner/researcher, gloves must be worn. Gloves must be replaced immediately if they become contaminated or damaged or defective in any way.
  • Disposable gloves must never be washed or decontaminated for reuse. All used gloves must be disposed of in proper waste receptacles.

Face Protection
Protection of the eyes and face is normally unnecessary except in situations where blood or contaminated fluids may be splashed into the eyes. Goggles or eyeglasses with solid side shields may be used for protection. Glasses without side shields are not sufficient. Masks in combination with eye protection devices such as goggles, glasses with side shields, or chin length face shields, are to be worn whenever there is potential for splashes, spray, spatter or droplets of blood or other potentially infectious materials.

Unit personnel wear whatever personal protective equipment (lab coat, gloves, gowns, face shield, etc.) is needed to prevent blood or other potentially infectious material from reaching their street clothes, skin, eyes, mouth, or other mucous membranes. Tasks and procedures in the Units that require use of additional personal protective equipment or clothing include:

Task/ProcedurePPE Required

Injections: Gloves/lab coat
Handling contaminated sharps: Gloves/lab coat
Handling contaminated waste: Gloves/lab coat
Exposure to open wounds: Gloves/lab coat
Minor eye trauma procedures: Gloves/lab coat
Removal of small masses from eyelidsL Gloves/lab coat/gown
Removal of ocular tissue: Gloves/lab coat/gown
Handling human tissue/blood products: Gloves/lab coat

PPE are readily accessible at these locations

Disposable gloves
Each clinic module, examination room & research unit

Lab coats
Each clinic module & research unit

Face Shields and Masks
Procedure rooms

Procedure rooms

PPE is removed prior to leaving the examination and/or procedure room and is placed in designated areas for disinfecting or disposal.

The following PPE disposal areas are available in these locations

Disposable gloves
Disposal units each clinic module & research unit

Lab coats and gowns
Hamper in procedure rooms

Face shields
Procedure room

Contaminated laundry is to be handled as little as possible. Contaminated laundry generated by this Unit should be placed and transported in bags or containers, which are appropriately labeled, or color-coded. At no time will Unit workers be expected to take home any PPE, including lab coats or gowns for laundering or cleaning.

Information and Training

Specific training may be conducted or provided by an appropriately designated individual which may include but is not limited to the Associate Dean of Clinic Affairs, Clinic Unit Chief, Clinical Faculty, PI, Unit Safety Officer or Departmental Safety Coordinator, with general assistance from Environmental Health and Safety (EH&S) and the Occupational Health Clinic (OHC) or via an online training program. Instruction will include information required by the Blood-borne Pathogens Standard and specific safety training for each person’s duties. Training may also include other material from the Injury and Illness Prevention Program.

In addition to reading the Blood-borne Pathogens Standard Exposure Control Plan, training and compliance with Universal Precautions as well as familiarity with the IIPP is suggested.

Signs and Labels

All examination and procedure areas as well as containers are labeled in accordance with the provisions of the Blood-borne Pathogens Standard. Labels used in this Unit for human blood and other potentially infectious materials must include the universal biohazard symbol and the term “biohazard” and must be fluorescent orange or orange-red in color.

Medical Surveillance Program (Hepatitis B Vaccination; Post-Exposure Evaluation and Follow-up)

The Occupational Health Clinic (OHC) in the University Health Service will provide appropriate required medical services.

Hepatitis B Vaccination

The Associate Dean of Academic Affairs will ensure that all persons in the Clinic Unit who are determined to have occupational exposure to blood-borne pathogens (see Exposure Control Plan, Section II-B – 1. and 2.) are offered Hepatitis B vaccination. Hepatitis B vaccination is an effective preventive measure against Hepatitis B infection.

Note: Only those individuals identified as covered under the terms of the Exposure Control Plan (see Exposure Control Plan Section II. B. 2.) will have the HBV series paid for by the Department. Students, staff and faculty not covered under the terms of the Exposure Control Plan must assume responsibility for the expense associated with the series.

Appointments are made by calling (510) 642-6891. The OHC professional staff will review work specifics, the chances of getting Hepatitis B, and the benefits and risks of the vaccination. Individual questions will be addressed.

Occupational Health Services will provide documentation that medical services have been provided as per the Blood-borne Pathogens Standard and in a manner that does not breach medical confidentiality. The Unit Chief or Departmental Safety Coordinator is to be informed when an individual has completed the HBV series.

For more information, Carole Plum, Occupational Health Nurse Practitioner, at 642-6891, may be contacted.

Hepatitis B Vaccination Declination

An individual may choose not to be vaccinated. A declination form must be obtained from the Department Safety Coordinator, located in room 381 Minor. The Department Safety Coordinator then keeps the declination form on file. If an individual declines the vaccination but later changes their mind, and the individual is still at risk of exposure to blood-borne pathogens, the individual may then receive the vaccination as outlined in Section G. 1.

Post-Exposure Evaluation and Follow-up

An exposure incident is any situation, such as a spill, splash, needle stick, ingestion, or accident, in which employees have direct, unprotected contact with human blood, fluids or tissue. If this happens, employees have the right to medical evaluation and treatment. These post-exposure services will be furnished to employees by OHC, at no cost, in accordance with the Blood-borne Pathogens Standard. In all instances involving unprotected exposure, follow emergency response procedures as described below.

In the event of direct exposure to human blood, fluids or tissue, immediately wash the affected body part with soap and water. When exposure occurs involving mucous membrane the area must be immediately rinsed with water only. In all instances the following should occur:

  • Students should immediately notify the Faculty member in charge of the Unit.
  • Staff should immediately notify their Supervisor.
  • Clinical Faculty should immediately notify the Clinic Chief.

After washing the exposed area, immediately go to the Occupational Health Clinic or to the Urgent Care Clinic at the University Health Service at Tang Center (located at 2222 Bancroft Way) promptly for medical treatment. OHC will assess the exposure and treat accordingly. Prompt medical attention may reduce the risk of serious health consequences after an exposure incident.


Every individual handling potentially contaminated material must report any exposure to these materials to the Unit Chief, Clinical Faculty member or Staff Supervisor. That individual (Unit Chief, Faculty member, Staff Supervisor) reports the incident immediately to the Department Safety Coordinator, EH&S and OHC. EH&S and OHC will investigate the circumstances surrounding the exposure, make recommendations for medical follow-up, and work with the Supervisor to modify work practices to prevent additional occurrences.

The primary responsibility for the evaluation of exposure incidents lies with the Department Safety Coordinator or Alternate with assistance from EH&S and OHC. The investigation will document the route of exposure and the circumstances under which the exposure incident occurred, and will make recommendations for modification in work practices to minimize or eliminate the potential of future exposure. (See Occupational Accident, Injury or Illness Investigation Report, IIPP Form 3). The corrective action team and departmental safety committees will also track the progress of any hazard correction activities (See Hazard Correction Report, IIPP Form 4).


For more information about the OSHA Blood-borne Pathogens Standard, this Exposure Control Plan, or for assistance in compliance, please contact EH&S at 642-3073.

Rev. Sept 2015