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Volume 85 - Fall 2003



Assuring Student Safety
Exposure Plans, Students, Faculty and Clinical Sites
by Karen Madsen Myers, PARC Vice-Chair and Terry Kotrla, PARC Member

All laboratory science curricula must assure student safety as a requirement of accreditation. Safety is addressed in program Standards under Sponsorship, as it relates to affiliation agreements, and under Students, in relationship to student health and safety.
It is worthwhile for programs to consider both training activities and implementation of the program's exposure plan in determining whether student safety is adequately addressed in the curriculum. A safety training and policy implementation checklist could include the following activities:

  • Student training focused on precautions regarding blood borne pathogens including use of required engineering and work practice controls.

  • A mechanism for assessing whether engineering and work practice controls are consistently used by students in all phases of the educational program.

  • An assessment of the program's exposure plan including the post-exposure evaluation and follow-up. This should include timely communication between the exposed student, school faculty or appropriate program contact, the clinical site as applicable, and a plan for the student to seek medical care and counseling and once an exposure occurs.

  • Student, faculty and clinical affiliate training regarding the program's exposure plan including steps students should follow after an exposure.

Schools may have an exposure plan and require that students use personal protective equipment, but if students, faculty and clinical sites are uninformed regarding these policies and procedures, outcomes may be less than ideal.

Consider the following scenarios:

    Situation #1: A student assigned to a 40-hour phlebotomy rotation receives a needle exposure. He informs his clinical coordinator of the exposure one week later after returning to classes at the college.
    Situation #2: A CLS student in a hematology rotation receives a mucous membrane exposure while preparing differential smears. While the student fails to wear safety glasses during the procedure, the student points out that none of the staff in the clinical department of the assigned rotation wear safety glasses.
    Situation #3: A student in an evening MLT/CLT laboratory course is exposed to a bloody peritoneal fluid. The evening contract faculty fills out the required exposure form and tells the student to take it to the program director the next morning when a follow-up protocol will be initiated.
    Situation #4: A clinical site sends a student who receives a needle stick from a contaminated sample to its own ER. Appropriate counseling, treatment and testing are initiated. Two months later the program receives a $700 bill for emergency services, which the program agrees to absorb because the student was not treated at a site designated by the school's health care program.
   These scenarios point to some critical considerations regarding training and implementation of policies around blood borne pathogen exposure: 1) How soon must students receive counseling, treatment and testing for exposure? Has the program made appropriate provisions for timely treatment, counseling, and testing for students who are in clinical rotations that are at a distance from school? 2) Do discrepancies exist between school policies and procedures and what occurs in practice? If there are discrepancies, are clinical faculty and students aware of the school policies regarding the use of personal protective equipment (PPE) that must be followed during clinical rotations? 3) Are there differences between how a school handles a blood borne pathogen exposure and how a clinical site handles a blood borne pathogen exposure, and are all clinical instructors aware of these differences? Do students know what to do according to school policy when they receive a blood borne pathogen exposure? 4) Since there is always a cost associated with treatment, counseling and post-exposure testing, does a clear process exist for handling the cost of such procedures?

Timely counseling and treatment for exposures

Students who are at risk of exposure to blood borne pathogens through a percutaneous injury or contact of mucous membranes or non-intact skin with potentially infectious body fluids or tissues need timely access to counseling, treatment and testing for hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV) if they become exposed. The CDC recommends that post-exposure treatment should begin as soon as possible after exposure, preferably within one to two hours, and no later than seven days.1 Counseling should always precede treatment. The post exposure prophylaxis (PEP) for each infectious agent varies, and programs must put in place an exposure plan that clearly explains post exposure counseling and treatment options. To assure student safety, programs need to insure that a mechanism exists for students to receive timely counseling, treatment, and testing and that all faculty who work with students, as well as all students, know the mechanism for initiating these services and the contact site where services will be rendered, and how expenses are to be paid, whether by the student, the site, or through insurance provided by the educational institution. The time frame for receiving counseling and treatment should be reflected in the program's exposure plan. Care may be dispensed through student or employee health services, an outside workman's compensation network, or the student's own physician.

Assuring students follow school policy during clinical rotations

The primary mechanism to prevent transmission of HBV, HCV and HIV in healthcare settings is to avoid occupational blood exposures.2 Hepatitis B vaccination, and engineering and work practice controls are an integral component of managing the rate of exposure. Educators tend to be quite stringent about the use of PPE during teaching laboratories. Students who enter a clinical site where practices are more lax may assume the habits of the clinical site without knowledge of the consequences of failure to follow school policies in the event of an exposure. It has been the authors' personal experience that most mucous membrane exposures occur during clinical rotations when students fail to wear safety glasses or other protective equipment. After more intense student training prior to entry into clinical rotations, enhanced communications with clinical sites regarding student use of PPE, and periodic audits of student PPE use during site visits, the number of mucous membrane exposures during clinical education has decreased. Educators can clearly specify the consequences of failure to use PPE in clinical rotations through strongly worded policies in the course syllabus including written warnings, removal from the clinical site as an unexcused absence, or immediate dismissal from the program.

Handling a student exposure during clinical education

Faculty at clinical sites needs to be informed of the program's policies and procedures regarding post-exposure processes. Most clinical facilities, unless instructed otherwise, will assume that students are to be treated in their employee health or emergency departments and will use the protocols established for employees of that facilities. However, the mechanism set up by a school for providing student coverage of exposure-related-care may be very different than that provided for employees. Most programs provide some type of on-site health care during didactic coursework and students can be directed to student or employee health when exposures occur. There are some exceptions to this rule. Even in hospital based programs where the distinction between student and laboratory employee is less obvious, for purposes of student health, students - as non-employees - may be covered by a workman's compensation policy which requires treatment by an outside clinic. Some colleges require students to carry their own health care insurance policy, and in such cases the exposed students must be directed in a similar timely manner to their own health care provider. Further, programs should always consider how counseling and treatment as well as testing will be initiated when students are in clinical rotations and not in daily contact with campus faculty and facilities.

Covering exposure related costs

Finally, there is the consideration of who will pay for costs incurred by exposure counseling, treatment and testing. While clinical sites once offered courtesy, no-cost counseling, treatment and initial testing for blood borne pathogen exposure, this benefit is disappearing. Programs need to be clear with students and clinical sites about the type of charges that can be generated post exposure under student health care arrangements and how these charges will be billed and paid. Students, faculty and clinical sites should be aware of the program's post-exposure protocol and follow practices that generate acceptable billings. While clinical sites may be able to participate in post-exposure counseling and treatment, if so defined under the provisions of the student health care arrangement, failure to follow the program's established protocol may result in out-of-pocket charges to either the student or the program.

Assuring student safety is more complex than simply providing orientation training covering blood borne pathogen exposure and PPE. Students as well as faculty and other personnel involved in the students' education should be made aware of the program's exposure plan and the mechanisms by which post-exposure counseling, treatment and testing is initiated. Assuring safety is about training and communication. Nowhere are such practices more evident than in programs for health care students, and especially those students involved in laboratory-related education where the potential for exposure is high.

1. CDC. Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIB and Recommendations for Post exposure Prophylaxis. June 29, 2001. Available at: http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5011a1.htm. Accessed September 10, 2003.
2. CDC. NIOSH alert: Preventing needlestick injuries in health care settings. Cincinnati, OH: Department of Health and Human Services, CDC, 1999; DHHS publication no. (NIOSH)2000-108.








Assuring Student Safety
Exposure Plans, Students, Faculty and Clinical Sites
by Karen Madsen Myers, PARC Vice-Chair and Terry Kotrla, PARC Member

Dr. NAACLS
Advice for Accredited and Approved Programs

Greetings From the new CLSPRC Chair
by Claudia Miller, PhD, MT(ASCP), CLS(NCA)
Chairman, NAACLS Clinical Laboratory Sciences Programs Review Committee

President's Report
Moving NAACLS to the Next Level of Excellence
by David D. Gale, PhD
President, NAACLS Board of Directors

Standard #1
Continuing Cause for Compliance Concerns
by Mary Jean Rutherford, MEd, MT(ASCP)SC
Past Chairman, NAACLS Clinical Laboratory Sciences Programs Review Committee



CEO's Corner
Making History
by Olive M. Kimball, PhD, EdD
NAACLS Chief Executive Officer



Attend the next NAACLS Workshop!

Board of Directors Update
(From the September 27, 2003 Meeting)






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