Aerosol Transmissible Disease Exposure Control Plan

SHC custodial staff that may encounter ATPs will be provided appropriate training to include proper cleaning and disinfection of building components including the isolation room (if one is available).  University Police who transport suspected or confirmed AirID cases will be provided with instructions on how to clean and disinfect their vehicles.

Specific control measures for CSUDH are identified below:

• Engineering controls include regular service intervals of building air handling and distribution systems in the SHC to ensure optimum performance of the building HVAC system.
• Work practice controls include regular in-service training for staff on the importance of proper hand washing practice, along with adoption of regulatory guidelines relative to the control of infectious disease in health care settings.
• Recommend and reinforce handwashing with soap and water for at least 20 seconds. If soap and water are not readily available, hand sanitizer that contains at least 60% alcohol can be used. Methanol Based hand sanitizers shall not be used.  To reinforce the hand wash behavior, independent hand sanitization stations are located throughout the Student Health Services building (e.g. touchless hand sanitizer stations placed by building doorways; handwashing stations positioned near high touch areas), along with instructions on use, and motivational literature designed to encourage hand sanitization etiquette.
• Encourage students, faculty, and staff to cover coughs and sneezes with a tissue or use the inside of the elbow. Used tissues should be thrown in the trash and hands washed immediately with soap and water for at least 20 seconds.

Hand Hygiene and Respiratory Etiquette

• Students, faculty, and staff are encouraged to cover coughs and sneezes with a tissue or use the inside of the elbow. Used tissues should be thrown in the trash and hands washed immediately with soap and water for at least 20 seconds.  If soap and water are not readily available, hand sanitizer that contains at least 60% alcohol can be used.
• CSUDH will ensure availability and access to supplies that promote healthy hygiene practices where appropriate (e.g., touchless hand sanitizer stations by building doorways; handwashing stations positioned near high touch areas).

Source control measures to be utilized in work areas where persons with suspected AirID symptoms are encountered:

• Persons with suspected AirID symptoms will be provided with disposable tissues, hand hygiene materials, and masked with a surgical or procedural mask, or placed in such a manner that contact with employees not wearing respiratory protection is eliminated or minimized until transfer or placement in an AII can be accomplished, or
• Persons with suspected AirID symptoms will be placed in an AII room or area or transferred to a facility with AII rooms or areas. The AII room will contain provisions for separate ventilation or filtration.  In most cases, CSUDH must ensure that transfer is performed within 5 hours of the identification of the case or suspected case.  Respiratory protection will be utilized by the campus Police during transport.
• All employees entering the AII room or area housing individuals with suspected AirID are provided with and use appropriate personal protective equipment including a N-95 respirator.
• At the SHC, individuals that require respiratory isolation, will be placed in room C-108, which has Negative Pressure ventilation. In such cases, SHC will keep the number of employees entering the isolation room to a minimum required to treat the patient.  Such employees will be properly protected with PPE, including N-95 masks as applicable and in accordance with 8CCR Section 5144 subsection (g), Respiratory Protection.
• Where it is not feasible to provide AII rooms or areas to individuals suspected or confirmed to be infected with or carriers of novel or unknown ATPs, CSUDH shall provide other effective control measures to reduce the risk of transmission to employees, which shall include the use of respiratory protection in accordance with Title 8 CCR 5199 subsection (g) and Section 5144, Respiratory Protection.

If the isolation room is not available or there are more individuals requiring isolation than reasonable to isolate in C-106, such individuals may be temporarily asked to wait, masked, outside the back of the SHC, until transport to a receiving facility can be arranged.

CSUDH will use the following procedures regarding isolation of employees who report AirID symptoms:

• Employees who suspect they are symptomatic of FLI or AirID are encouraged to stay home and seek treatment from their normal healthcare providers. Employees who have FLI symptoms should self-isolate from other family members, practice good hand hygiene, use source control methods (surgical masks) when around other family members, and remain away from work or public gatherings until 48 hours after fever and symptoms have abated.
• A person requiring referral will be placed in a separate room or area with separate ventilation or filtration.
• If employees plan to enter the room or area in which the person requiring referral is located (if that person is not compliant with source control measures) then a respirator will be used in accordance with Title 8, Section 5144, Subsection (g), Respiratory Protection.
• Campus police who transport a person requiring referral must wear a respirator unless all of the below conditions are met:
  • A solid partition separates the passenger area from the area where employees are located;
  • If written procedures have been implemented that specify the conditions of operation, including the operation of windows and fans;
  • If tests (e.g., by the use of smoke tubes) assess the airflow in a representative vehicle (of the same model, year of manufacture, and partition design) under the specified conditions of operation, and finds that there is no detectable airflow from the passenger compartment to the employee area;
  • If results of the tests are recorded and maintained in accordance with Title 8, 5199, subsection (j)(3)(F); and
  • The person performing the test is knowledgeable about the assessment of ventilation systems.
• Immediately separate faculty, staff, and students with ATD symptoms(such as fever, cough, or shortness of breath). Individuals who are sick should go home or to a healthcare facility, depending on how severe their symptoms are, and follow CDC Guidance for caring for oneself and others who are sick. CSUDH may follow CDC’s Guidance for Shared or Congregate Housing for those that live in campus housing.
• Campus administrators should immediately provide options to separate people with ATD symptoms by providing distance learning options, self-isolation rooms in dormitories or other housing facilities, and food delivery service for on-campus students in self-isolation.
• Employees who report to work, and later develop AirID symptoms will be encouraged by their supervisors or appropriate administrators to take sick leave and remain away from work until fever and symptoms have abated.

The SHC treats only normally matriculated students, and as such does not treat employees, (except in cases of urgent or emergent situations, for the purpose of stabilization prior to referral out or transport).  Isolation procedures established by the SHC for students who present with AirID symptoms are described above, see Source Control Measures. After initial contact with the clinician, if it is determined that it is appropriate for the student to isolate at home, the following apply:

• If patient does not reside on campus housing, patient will be advised to go home and self-isolate until no longer symptomatic.

If patient is housed on campus, the SHC will contact Student Housing and advise that a resident is symptomatic for AirID.  The patient/student will be housed in a single room, equipped with a dedicated ventilation and heating system until no longer symptomatic.

Employee medical services are provided by CSUDH through a contracted occupational medical provider, Concentra. Required vaccinations are offered to clinicians and employees with potential occupational exposure including MDs, NPs, RNs, LVNs, University Police Officers, and select employees that may perform cleaning or maintenance at the SHC, including the isolation room.  An employee who is offered required vaccinations, but declines, is required to sign a declination of vaccination form, which becomes a part of the employee’s permanent medical record.  If a required vaccine is requested by CSUDH from the contracted medical provider, and there is a delay in vaccine delivery, the contracted medical provider will provide a written declaration to CSUDH that the vaccine is unavailable and provide an estimate of when the vaccine will be available.

CSUDH will also offer vaccinations against seasonal influenza to all employees with occupational exposure, during the period designated by the CDC for administration.

If CSUDH is informed that an employee may have a reportable aerosol transmissible disease (RATD) or has been exposed to someone who may have a RATD, the following actions shall be taken:

• Within 72 hours of the time CSUDH was informed regarding the potential occupationally related exposure, the pertinent facts surrounding the exposure will be gathered by the appropriate administrator to determine if a significant exposure may have occurred (significant exposure means working within six feet of a suspected AirID person, or being directly exposed to aerosol droplets from a person with suspected AirID). This report and subsequent required reporting and decision making shall be conducted by a campus employee with demonstrated knowledge of epidemiology and the methods for controlling infectious disease exposure.  If a determination is made that a significant exposure to a CSUDH employee has not occurred, and that no post-exposure prophylaxis is required, the information used to make that determination shall be documented.
• Within 96 hours of the significant exposure, CSUDH shall notify employees in adjacent work stations regarding the nature of the potential exposure.

As soon as feasible, CSUDH shall provide post-exposure medical evaluations to employees who may have had a significant exposure to the index case. The medical evaluation shall be performed by the CSUDH occupational medical provider.

CSUDH will assess each suspected exposure incident involving an employee according to established incident investigation protocols detailed in the CSUDH Injury and Illness Prevention Program.  Refer to that document for written procedures.

CSUDH will maintain contact with the facility who received the referred patient to obtain necessary infection control information so that it can be provided to employees who were exposed to the referred patient.

Managers and supervisors shall maintain current public health information provided by CSUDH on AirID cases at CSUDH.  Employees that may have occupational exposure to AirID suspected or confirmed cases must be briefed on these cases. The briefings shall be recorded in writing and maintained as required by CSU Record Retention guidelines.

Cases or suspected cases of specific AirIDs must be reported to the local health officer per Title 17 CCR §2500.  The CSUDH ATD Program Administrator is responsible to ensure the reporting requirements to the local health officer are fulfilled, and will designate an employee with a medical background (i.e. SHC employee, Concentra employee) to do so, depending on the situation. All HIPAA (Health Insurance Portability and Accountability Act) guidelines regarding patient confidentiality will be observed as required.

Reporting requirements and details on which AirIDs must be reported is available at http://publichealth.lacounty.gov/cdcp/proreporting.htm

The SHC, University Police, and any additionally identified campus departments or offices where occupational exposure to AirID may occur will procure and maintain adequate supplies of NIOSH-approved N-95 respirators in required sizes.  Methods for ensuring adequate supplies shall be developed by the identified departments based on the following general guideline.  

Departments will maintain a list of medically evaluated, fit tested, and trained employees that are approved by EHS to wear a respirator and are included in the CSUDH Respiratory Protection Program per Title 8 CCR §5144. Each department shall maintain a supply of N-95 respirators sufficient to supply one respirator per covered employee per shift, plus 5% for additional incidental use.

In addition, SHC clinical staff will be provided with eye protection, disposable gowns, and non-latex single-use gloves Other job classifications with occupational exposure risk for AirID will be provided with non-latex gloves.

All employees with occupational exposure to ATPs must be trained on this plan.  All personnel must be informed of the hazards associated with the work performed and proper safety precautions.  ATD training is required at the time of initial assignment to tasks where occupational exposure may occur and at least annually thereafter.  In addition, training is required when changes occur in procedures that could affect worker exposure to ATPs, such as the introduction of new engineering or work practice controls or modification of tasks and procedures.

This training includes:

• A general explanation of ATDs including the signs and symptoms that require further medical evaluation;
• Screening methods and criteria for persons who require referral;
• CSUDH’s source control measures and how these measures will be communicated to persons the employees contact;
• CSUDH’s procedures for making referrals;
• Procedures for temporary risk reduction measures prior to transfer;
• Training when respiratory protection is used;
• CSUDH’s medical services procedures, the methods of reporting exposure incidents, and procedures for providing employees with post-exposure evaluation;
• Information on vaccines that will be made available, including the seasonal influenza vaccine. For each vaccine, this information will include the efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;
• How employees can access CSUDH’s written procedures and how employees can participate in reviewing the effectiveness of the procedures; and
• An opportunity for interactive questions and answers with a person who is knowledgeable in the subject matter as it relates to the workplace that the training addresses and who is also knowledgeable in CSUDH’s infection control procedures. Training not given in person will provide for interactive questions to be answered within 24 hours by a knowledgeable person.

Infection control procedures are reviewed at least annually by the administrator and by employees regarding the effectiveness of the program in their respective work areas, and deficiencies found will be corrected.

CSUDH will maintain training records, vaccination records, records of exposure incidents, and records of inspection, testing, and maintenance of non-disposable engineering controls.  Where respirators are used, CSUDH will maintain records of implementation of the Respiratory Protection Program in accordance with Title 8, Section 5144, Respiratory Protection.

Medical records generated by employees treated for occupationally acquired illnesses will be maintained as required and stipulated in the Employee Medical Monitoring Plan and by the CSU System Executive Order 1031.  HIPPA provisions govern the maintenance and access to employee medical records.

Training records shall be maintained for 3 years from the date on which the training occurred and include the following information:

• The date(s) of the training session(s);
• The contents or a summary of the training session(s);
• The names and qualifications of persons conducting the training or who are designated to respond to interactive questions; and
• The names and job titles of all persons attending the training sessions.

Annual Review

Records of annual review of the ATD Plan and Biosafety Plan shall include the name(s) of the person conducting the review, the dates the review was conducted and completed, the name(s) and work area(s) of employees involved, and a summary of the conclusions. The record shall be retained for three years.

Records of exposure incidents shall be retained and made available as employee exposure records in accordance with Title 8, Section 3204. These records shall include:

• The date of the exposure incident;
• The names, and any other employee identifiers used in the workplace, of employees who were included in the exposure evaluation;
• The disease or pathogen to which employees may have been exposed;
• The name and job title of the person performing the evaluation;
• The identity of any local health officer and/or Physician or Other Licensed Health Care Professional (PLHCP) consulted;
• The date of the evaluation; and
• The date of contact and contact information for any other employee who either notified the employer or was notified by the employer regarding potential employee exposure.

Records of the unavailability of a vaccine shall include the name of the person who determined that the vaccine was not available, the name and affiliation of the person providing the vaccine availability information, and the date of the contact. This record shall be retained for three years.

Records of the unavailability of AII rooms or areas shall include the name of the person who determined that an AII room or area was not available, the names and the affiliation of persons contacted for transfer possibilities, and the date of the contact, the name and contact information for the local health officer providing assistance, and the times and dates of these contacts. This record, which shall not contain a patient's individually identifiable medical information, shall be retained for three years.

CSUDH does not perform in-patient medical care for patients with ATD’s and therefore there is no requirement to keep records of decisions not to transfer patients to another facility. All patients requiring transfer will be sent for a higher level care.

Records of inspection, testing and maintenance of non-disposable engineering controls including ventilation and other air handling systems, air filtration systems, containment equipment, biological safety cabinets, and waste treatment systems shall be maintained for a minimum of five years and shall include the name(s) and affiliation(s) of the person(s) performing the test, inspection or maintenance, the date, and any significant findings and actions that were taken.

Records of the respiratory protection program shall be established and maintained in accordance with Title 8, Section 5144, Respiratory Protection.  Employers who provide fit-test screening, in accordance with the exception to subsection (g)(6)(B)3 shall retain the screening record for two years.

Availability

CSUDH shall ensure that all records required to be maintained shall be made available upon request to the Cal/OSHA and NIOSH and the local health officer for examination and copying.

Employee training records, the exposure control plan and/or biosafety plan, and records of implementation of the ATD exposure control plan and biosafety plan, other than medical records containing individually identifiable medical information, shall be made available as employee exposure records in accordance with Title 8, Section 3204(e)(1) to employees and employee representatives.

Employee medical records required shall be provided upon request to the subject employee, anyone having the written consent of the subject employee, the local health officer, and to the Chief and NIOSH in accordance with Section 3204 of these orders, Access to Employee Exposure and Medical Records, for examination and copying.

Transfer of Records

CSUDH will comply with the requirements involving the transfer of employee medical and exposure records that are set forth in Title 8, Section 3204, Access to Employee Exposure and Medical Records, of these orders.

If CSUDH ceases to do business and there is no successor employer to receive and retain the records for the prescribed period, CSUDH shall notify the Cal/OSHA and NIOSH, at least three months prior to the disposal of the records and shall transmit them to NIOSH, if required by NIOSH to do so, within that three-month period.

This plan will be annually reviewed for effectiveness by the Program Administrator and/or whenever processes change. The CSUDH campus Health & Safety committee meets at least quarterly and will review these procedures as needed.  Employees or their representatives interested in improving the procedures contained in this plan may participate in these committee meetings by contacting the Program Administrator.

CSUDH will not provide surge capacity services (rapid deployment of experienced coordination experts).  Surge procedures on campus will be guided by Los Angeles County Public Health and the CSU Chancellor’s Office.