Environmental Hazards and Occupational Exposure Policy

Purpose
To addresses medical student occupational exposures to infectious and environmental hazards, including methods of prevention, procedures for care and treatment after exposure (including a definition of financial responsibility), and the effects of infectious and environmental disease or disability on medical student learning activities. All medical students and visiting students must be informed of these policies before undertaking any educational activities at UC Davis School of Medicine (e.g., the School) and/or its affiliated institutions that would place students at risk.

Audience
All medical students, including visiting students, faculty, and staff responsible for implementing this policy and its procedures

LCME Standard
12.8: Student Exposure Policies/Procedures - A medical school has policies in place that effectively address medical student exposure to infectious and environmental hazards, including the following:

  1. The education of medical students about methods of prevention
  2. The procedures for care and treatment after exposure, including a definition of financial responsibility
  3. The effects of infectious and environmental disease or disability on medical student learning activities

Policy

Definitions

  • Bloodborne Pathogens, as defined by the Occupational Safety and Health Administration (see 29 C.F.R. § 1910.1030), are pathogenic microorganisms that are present in human blood that can cause disease in humans. These include, but are not limited to, Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV) and Hepatitis C Virus (HCV).
  • Occupational Exposure, as defined by the Occupational Safety and Health Administration (see 29 C.F.R. § 1910.1030), is a reasonably anticipated skin, eye, mucous membrane, or parenteral contact with human blood or Other Potentially Hazardous (including biological, radiation, and chemical) Materials that may result from the performance of an individual’s work duties.
  • Other Potentially Infectious Materials, as defined by the Occupational Safety and Health Administration (see 29 C.F.R. § 1910.1030) include: Semen and vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid pericardial fluid; peritoneal fluid, amniotic fluid; saliva in dental procedures; any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; any unfixed tissue or organ (other than intact skin) from a human (living or dead); HIV-containing cell or tissue cultures, organ cultures, and HIV or HBV-containing culture media or other solutions; blood, organs, or other tissues from experimental animals infected with HIV or HBV.
  • Visiting Student is a non-UC Davis student that is enrolled at another medical school and participating in graded clinical elective learning experiences that are sponsored by the School.
  1. Read and acknowledge UC Davis Health Policy 2167 Blood Body Fluid Exposure (Needlesticks)
  2. Read and acknowledge  UC Davis Health Blood Borne Pathogen Exposure Control Plan, and policy on aerosol transmissible diseases on the UC Davis Safety Services Website
  3. Read and acknowledge UC Davis Health Education and Research Injury and Illness Prevention Program and its Appendix
  4. Read and acknowledge UC Davis Health Biological Hazards – Recognition, Evaluation and Control
  5. Read and acknowledge UC Davis Health Radiation Hazards
  6. Read and acknowledge UC Davis Health Chemical Hazards

Procedure

  1. Education
    1. All students are required to complete online Occupational Health training modules once they are assigned by the Registrar’s Office. The training modules will be assigned the first quarter the student is enrolled in the M.D. program and must be renewed annually. The Registrar’s Office tracks module completion.
    2. At the beginning of each academic year prior to any clinical rotations students are required to read and acknowledge school policies, including both the UC Davis School of Medicine and the UC Davis Health Occupational Exposures Policies and reporting procedure information.
    3. Prior to participating in clinical clerkships at the beginning of their third year of medical school, all students are required to participate in the Transition to Clerkships (T2C) Course. During this training, both the UC Davis School of Medicine and the UC Davis Health Occupational Exposures Policies and reporting procedures are shared with them.
    4. Prior to participating in clinical elective learning experiences, the School’s Registrar’s Office will provide all visiting students with both the UC Davis School of Medicine and the UC Davis Health Occupational Exposures Policies and reporting procedure information.
  2. Care, Treatment and Financial Responsibility

    During first quarter orientation and the T2C course, students are instructed to immediately report all infectious and environmental hazard exposures to the Associate Dean for Students.

    1. Exposure at UC Davis Health: During T2C, the students are instructed to follow the UC Davis Health procedures outlined in Policy 2167. This policy outlines the four steps (Decontaminate, File Online Exposure Report, Obtain HIV Consent and Contact Bloodborne Pathogen Exposure Nurse), as well as after-hour instructions. The student will not incur any costs related to an onsite exposure.
    2. Exposure at a Non-UC Davis Health Site: 
      1. If a needle stick or exposure occurs while a UC Davis medical student is at a Non-UC Davis Health site, immediate evaluation and treatment will be available within the guidelines and policies of that institution or facility. Students may be referred to a local emergency department. Students are encouraged to contact the Associate Dean for Students or their primary care physician for reporting and follow-up as soon as they are able to do so. Any treatment or laboratory cost associated with the initial exposure management and treatment should be submitted by the student to his or her health care insurer. Students at a Non-UC Davis Health site should follow the above procedures for reimbursement of uncovered medical expenses. 
      2. As outlined in the AAMC standard affiliation agreement, the HOST Agency agrees to the following: "The HOST AGENCY agrees to comply with applicable state and federal workplace safety laws and regulations. In the event a student is exposed to an infectious or environmental hazard or other occupational injury (i.e., needle stick) while at the HOST AGENCY, the HOST AGENCY, upon notice of such incident from the student, will provide such emergency care as is provided its employees, including, where applicable: examination and evaluation by HOST AGENCY’s emergency department or other appropriate facility as soon as possible after the injury; emergency medical care immediately following the injury as necessary; initiation of the HBV, Hepatitis C (HCV), and/or HIV protocol as necessary; and HIV counseling and appropriate testing as necessary. In the event that HOST AGENCY does not have the resources to provide such emergency care, HOST AGENCY will refer such student to the nearest emergency facility."
      3. Any costs incurred for treatment should be submitted by the student to their insurance company. Any costs not covered by the insurance company will then be paid by the School of Medicine either through direct pay to the company or through reimbursement of the student. The School’s primary insurance provider is Western Health Advantage which requires a $100 co-pay for emergency room visits, both locally and out of the service area. The School of Medicine will also reimburse the student for the co-pay. 
    3. Visiting Students are required to maintain active health insurance coverage to fund all health needs related to Occupational Exposure and must utilize their health insurance to cover the necessary care and treatment expenses due to such Exposure, including evaluation, testing, and treatment costs.
  3. Effects on medical student learning: Students who are infected with any other potentially transmissible disease will not be excluded from participating in patient-care activities, or restricted in their access to patient-care services or facilities because of their health status, unless medically-based judgments in individual cases establish that exclusion or restriction is appropriate for the welfare of patients, the welfare of other members of the patient-care community, or the welfare of the individual. The Associate Dean of Students, in conjunction with Employee Health Services, will counsel the student if a diagnosis does interfere with their ability to continue in the program.

Responsibility
Associate Dean of Students

References

UC Davis Health Policy 2167 Blood Body Fluid Exposure
UC Davis Health Blood Borne Pathogen Exposure Control Plan
UC Davis Health Policy on Aerosol Transmissible Diseases
UC Davis Health Education and Research Injury and Illness Prevention Program and Appendix
UC Davis Health Biological Hazards – Recognition, Evaluation and Control
UC Davis Health Radiation Hazards
UC Davis Health Chemical Hazards
T2C PIV and Phlebotomy Faculty Guide
Medical student compliance with administrative tasks policy

Policy Owner
Associate Dean of Students

Reviewed By
Associate Dean of Students*
Assistant Dean for Medical Education
Director of Curriculum and Educational Technology

Reviewed Date and Review Cycle
April 2023; 3 year review

*indicates the policy owner