By Ed Jacques, LEJ Editor
Michigan HIV laws define “exposure” as sustaining a percutaneous, mucous membrane, or open wound exposure to the blood or other body fluids of another. The Occupational Safety and Health Administration (OSHA) has implemented the following requirement on employers regarding training, equipment, vaccinations, exposure follow up and record keeping.
- Annual training of employees on bloodborne pathogens, exposure situations, engineering controls and safeguards.
- Use and availability of personal protection equipment.
- Exposure control plan
- Hepatitis B vaccinations
- Blood collection and testing for employee and source individual after exposure incident
- Follow-up care and counseling
- Training and exposure records.
When researching this topic, I asked POAM Executive Board members if they could recommend a local officer in their department who could lend advice on how such programs should be implemented. I was put in touch with David Ziegler, Exposure Control Officer with the Taylor Police Department.
Ziegler informed me that the city of Taylor was in full compliance with all state and federal laws, and has provided additional resources to further ensure the safety of its first responders. The city consistently sends employees to training and has developed its own protocol for responding to an exposure. The Center for Disease Control (CDC) calls for a maximum of eight hours to provide remedy. Taylor’s safety committee meets regularly with its police and fire administration and has established a plan to treat affected personnel within two hours. “The employer is obligated to vaccinate and blood test any employee reasonably expected to be exposed,” says Dave.
When an exposure occurs, the affected first responder is immediately sent to the hospital. Ziegler is then contacted to work with the officer and the clinic. Dave documents that the proper criteria has been met and insures that all follow- up visits are adhered to. Quick response to the incident increases the odds that a disease will not be converted, especially in a high exposure incident.
The city has provided Ziegler with a laptop computer with existing health-related information on employees as well as a database program for entering vaccinations, exposure history, TB tests, allergies, and training history. The employer does not have access to the information and federal law states that the employee exposure officer cannot supervise an affected employee. OSHA’s record keeping requirements are strict and comprehensive. Training and exposure records must be kept for the duration of employment plus 30 years!
The department’s personal protection “kit” includes a gown, face mask and eye shield, rubber gloves, alcohol type cleaner and disposal bag. Protective wear must be worn at all reasonable times. Taylor stores the equipment in their jail and in all patrol cars.
Ziegler is immediately notified of any possible exposure and is also responsible to make sure all follow-up care and counseling is performed. According to Dave, “The series of prophylaxis drugs necessary in a high-risk, high-exposure case is hell on earth, and includes a six-month process of drawing blood.”
A large portion of Dave’s expertise involves knowledge of Michigan’s HIV laws and making sure that local hospitals and clinics are cooperating with their consent for treatment forms, the exemptions to informed consent, and a first responder’s request for HIV testing. In a nutshell, health care professionals must post notice of its right to perform HIV tests and inform any person possibly exposed of its results AND honor any first responder’s request to test the emergency patient for HIV and Hepatitis B, in case of exposure.
The city of Taylor has also designated an OSHA Compliance Officer, Fire Captain Herb Protector, who has assisted the administration in implementing its program and training of all first responders. “The city of Taylor and Chief Dale Tamsen’s commitment to implement this all encompassing program shows how much they care about their employees’ welfare,” said Ziegler.
Dave stressed that his fellow employees have responsibilities that have to be met. “They need to attend all training classes, notify the employer when any possible exposure takes place and make all their follow-up sessions.” Ziegler encourages members to use their PPE kit, know their exposure plan and get the hepatitis vaccination series, if necessary. “Above all,” says Dave, “protect yourself at all times.”
Ziegler hopes that all municipalities are in the process of complying with the federal statute. “OSHA and the Michigan Department of Community Health have websites and all the appropriate information.” If anyone needs some special coaching on this issue, they can call Dave at the Taylor Police Department.