Universal precautions (UP) are intended to prevent transmission of infection, as well as decrease the risk of exposure for employees and students.  It is not currently possible to identify all infected individuals, thus precautions must be used with every individual.  UP pertain to blood and other potentially infectious materials (OPIM) containing blood.  These precautions do not apply to other body fluids and wastes (OBFW) such as saliva, sputum, feces, tears, nasal secretions, vomitus and urine unless blood is visible in the material.  However, these OBFW can be sources of other infections and should be handled as if they are infectious.  The single most important step in preventing exposure to and transmission of any infection is anticipating potential contact with infectious materials in routine as well as emergency situations.  Based on the type of possible contact, employees and students should be prepared to use the appropriate precautions prior to the contact.  Diligent and proper hand washing, the use of barriers, appropriate disposal of waste products and needles, and proper decontamination of spills are essential techniques of infection control.  All individuals should respond to situations practicing UP followed by the activation of the school response team plan.  Using common sense in the application of these measures will enhance protection of employees and students.

Hand Washing

Proper hand washing is crucial to preventing the spread of infection.  Textured jewelry on the hands or wrists should be removed prior to washing and kept off until completion of the procedure and the hands are rewashed.  Use of running water, lathering with soap and using friction to clean all hand surfaces is key.  Rinse well with running water and dry hands with paper towels.

• Hands should be washed before physical contact with individuals and after contact is completed.
• Hands should be washed after contact with any used equipment.
•  If hands (or other skin) come into contact with blood or body fluids, hands should be washed immediately before touching anything else.
• Hands should be washed whether gloves are worn or not and, if gloves are worn, after the gloves are removed.  

Barriers

Barriers anticipated to be used at school include disposable gloves, absorbent materials and resuscitation devices.  Their use is intended to reduce the risk of contact with blood and body fluids as well as to control the spread of infectious agents from individual to individual.  Gloves should be worn when in contact with blood, OPIM or OBFW.  Gloves should be removed without touching the outside and disposed of after each use.

Disposal of Waste

Blood, OPIM, OBFW, used gloves, barriers and absorbent materials should be placed in a plastic bag and disposed of in the usual procedure.  When the blood or OPIM is liquid, semi-liquid or caked with dried blood, it is not absorbed in materials, and is capable of releasing the substance if compressed, special disposal as regulated waste is required.  A band-aid, towel, sanitary napkin or other absorbed waste that does not have the potential of releasing the waste if compressed would not be considered regulated waste.  It is anticipated schools would only have regulated waste in the case of a severe incident.  Needles, syringes and other sharp disposable objects should be placed in special puncture-proof containers and disposed of as regulated waste.  Bodily wastes such as urine, vomitus or feces should be disposed of in the sanitary sewer system.

Clean up

Spills of blood and OPIM should be cleaned up immediately.  The employee should:

    •     Wear gloves. 

    •    Clean up the spill with paper towels or other absorbent material.

    •    Use a solution of one part household bleach to one hundred parts of water (1:100) or other EPA-approved disinfectant and use it to wash the area well.

    •    Dispose of gloves, soiled towels and other waste in a plastic bag.

    •    Clean and disinfect reusable supplies and equipment.

Laundry

Laundry with blood or OPIM should be handled as little as possible with a minimum of agitation.  It should be bagged at the location.  If it has the potential of releasing the substance when compacted, regulated waste guidelines should be followed.  Employees who have contact with this laundry should wear protective barriers.

Exposure

An exposure to blood or OPIM through contact with broken skin, mucous membrane or by needle or sharp stick requires immediate washing, reporting and follow-up.

    •    Always wash the exposed area immediately with soap and water.

    •    If a mucous membrane splash (eye or mouth) or exposure of broken skin occurs, irrigate or wash the area thoroughly.

    •    If a cut or needle stick injury occurs, wash the area thoroughly with soap and

        water.

The exposure should be reported immediately, the parent or guardian is notified, and the person exposed contacts a physician for further health care.

Approved 8/18/11     Reviewed  10/21/20              Revised            

EMPLOYEES ARE HEREBY NOTIFIED it is a violation of the Substance-Free Workplace policy for an employee to unlawfully manufacture, distribute, dispense, possess, use, or be under the influence of in the workplace any narcotic drug, hallucinogenic drug, amphetamine, barbiturate, marijuana or any other controlled substance or alcohol, as defined in Schedules I through V of section 202 of the Controlled Substances Act (21 U.S.C. 812) and as further defined by regulation at 21 C.F.R. 1300.11 through 1300.15 and Iowa Chapter 124.

"Workplace" is defined as the site for the performance of work done in the capacity as an employee.  This includes school district facilities, other school premises or school district vehicles.  Workplace also includes non school property if the employee is at any school-sponsored, school-approved or school-related activity, event or function, such as field trips or athletic events where students are under the control of the school district or where the employee is engaged in school business.

Employees who violate the terms of the Substance-Free Workplace policy may be required to successfully participate in a substance abuse treatment program approved by the board. The superintendent retains the discretion to discipline an employee for violation of the Substance-Free Workplace policy.  If the employee fails to successfully complete participation in such a program the employee shall be subject to discipline up to and including termination.

EMPLOYEES ARE FURTHER NOTIFIED it is a condition of their continued employment that they comply with the above policy of the school district and will notify their supervisor of their conviction of any criminal drug statute for a violation committed in the workplace, no later than five days after the conviction.

SUBSTANCE-FREE WORKPLACE ACKNOWLEDGMENT FORM

I, ______________________________, have read and understand the Substance-Free Workplace policy.  I understand that if I violate the Substance-Free Workplace policy, I may be subject to discipline up to and including termination or I may be required to participate in a substance abuse treatment program.  If I fail to successfully complete participation in a substance abuse treatment program, I understand I may be subject to discipline up to and including termination.  I understand that if I am required to participate in a substance abuse treatment program and I refuse to participate, I may be subject to discipline up to and including termination.  I also understand that if I am convicted of a criminal drug offense committed in the workplace, I must report that conviction to my supervisor within five days of the conviction.

                                                                                                 _                                       

 (Signature of Employee)                                                                          (Date) 

Approved 8/18/11     Reviewed    10/21/20            Revised            

When the superintendent suspects an employee has a substance abuse problem the following  procedures will be followed.

     1.    Identification - the superintendent shall document the evidence the

        superintendent has which leads the superintendent to conclude the

         employee has violated the Substance-Free Workplace policy.  After the

        superintendent has determined there has been a violation of the Substance-

         Free Workplace policy, the superintendent shall discuss the problem with

        the employee. 

     2.    Discipline - if, after the discussion with the employee, the superintendent

        determines there has been a violation of the Substance-Free Workplace

        policy, the superintendent may recommend discipline up to and including

        termination or may recommend the employee seek substance abuse

        treatment.  Participation in a substance abuse treatment program is

        voluntary. 

    3.    Failure to participate in referral - if the employee refuses to participate in a

        substance abuse treatment program or if the employee does not

        successfully complete a substance abuse treatment program, the employee

        may be subject to discipline up to and including termination.

    4.     Conviction - if an employee is convicted of a criminal drug offense

        committed in the workplace, the employee must notify the employer of

         the conviction within five days of the conviction.

Approved 8/18/11     Reviewed   10/21/20             Revised   10/21/20         

EMPLOYEE PERSONAL ATTESTATION OF VACCINATION STATUS

I, ____________________ as an employee of the District do personally attest to the following:

1. My vaccination status for COVID-19 is ________________ [fully vaccinated or partially vaccinated].

2. To the best of my recollection, I can provide the following information about my vaccination status:  ___________________________ [type of vaccine administered, date(s) of administration, name of health care providers and clinic site]

3. I have lost proof of my vaccination status and am otherwise unable to provide proof of my vaccination status.

4. I declare that this statement about my vaccination status is true and accurate.  I understand that knowingly providing false information regarding my vaccination status on this form may subject me to criminal penalties. 

    ___________________________________  ________________________

          Employee                                                                        Date

MEDICAL ACCOMMODATION REQUEST FORM

(1) What is the basis for the medical accommodation that you are requesting?

(2) What are you requesting an accommodation from?

___________________________________  ________________________________

Employee Signature                                                    Date

          --------------------------------------------------------------------------

                                           Office Use

This request has been:

______________________________  ________________________________

Approved                                                             Denied

_______________________________  ______________________________

          Administrator                                                                Date

(1) Please identify the policy requirement or practice that conflicts with your sincerely held religious observance, practice or belief:

(2) Please describe the nature of your sincerely held religious beliefs or religious practice or observance that conflict with the policy or practice you have identified above:

(3) What are you requesting an accommodation from?

___________________________________  ________________________________

Employee Signature                                                        Date

--------------------------------------------------------------------------------

Office Use

This request has been:

______________________________  ________________________________

Approved                                                               Denied

         ______________________________  ______________________________

Administrator                                                          Date

Acceptable Proof of Vaccination Status

To satisfy the vaccination requirement within this policy, employees must submit to the Superintendent or Superintendent’s designee acceptable proof of vaccination status no later than December 6, 2021.  Acceptable proof of vaccination status includes:

1. Immunization records from a healthcare provider or pharmacy;
2. A copy of a COVID-19 Vaccination Record Card;
3. A copy of medical records documenting immunization;
4. A copy of immunization records from a public health, state or tribal immunization information system;
5. Any other official documentation that contains the type of vaccine administered, dates of administration, and the name of the administering health provider or clinic;
6. If any other records are unavailable a signed and dated personal attestation statement.

Any employee who fails to provide acceptable proof of vaccination status may face disciplinary action up to and including termination.

Record Keeping

The district is required by law to keep a roster of the vaccination status of all employees. 

Any records showing proof of employee vaccination status the district maintained prior to November 5, 2021 will be considered sufficient proof of the employee’s vaccination status.

Any records related to an employee’s vaccination status, including the employee vaccination status roster, will be considered confidential employee medical records not subject to public disclosure and stored as employee medical records consistent with law.  These records will be maintained by the district for as long as 29 C.F.R. 1910.501remains in effect.

Testing

Beginning January 4, 2022, employees who are not fully vaccinated must submit proof of negative COVID-19 test results every 7 days.  Documentation of negative test results must be provided to the district no later than every 7 days.  Employees who are not fully vaccinated and do not report to work for longer than 7 days (ex. an employee on vacation or on leave) must provide documentation of a negative test result upon their return to work.  If the employee fails to provide proof of a negative test result, the district must keep the employee removed from the workplace until the negative test result documentation is provided.

Employees who receive a positive COVID-19 test result or have been diagnosed with COVID-19 by a licensed healthcare provider; are not required to produce another test

result for 90 days from the date of their positive result. 

Positive Test Results

Regardless of vaccination status, employees must report any positive COVID-19 test results or a diagnosis of COVID-19 by a licensed healthcare provider to the district.  Any employee so reporting will be immediately removed from the workplace and will stay removed from the workplace until any of the following occur:

• The employee receives a negative result on a COVID-19 nucleic acid amplification test (NAAT) following a positive result on a COVID-19 antigen test if the employees chooses to seek the confirmatory test
• The employee meets the return to work criteria in the CDC’s “Isolation Guidance” listed here: https://www.cdc.gov/coronavirus/2019-ncov/your-health/quarantine-isolation.html
• The employee receives a recommendation to return to work from a licensed healthcare provider.

New Employees

New employees will be subject to the provisions of this policy upon hire as soon as practicable.  Within 7 days of hire, new employees will provide proof of their vaccination status to the district in accordance with the requirements of this policy.  Unless fully vaccinated, new employees will abide by the testing and face covering requirements of this policy within 7 days of hire. 

Leave

As required by 29 C.F.R. 1910.501, the district will provide up to 4 hours of paid leave to cover the time required to travel to and obtain each dose of the primary vaccination for COVID-19.  If additional time is required, the employee may use other accrued leave available.  The district will also provide reasonable paid sick leave to employees to recover from any effects of each primary dose of COVID-19 vaccine.  The district will require employees to use previously accrued paid sick leave first.

Employees Excluded

Employees who work fully remote from the job site; employees working from home; and employees who work exclusively outdoors are excluded from the vaccination, testing and face covering requirements of this policy.  Employees fully remote from the job site does not include employees whose work requires them to work off site from the district but in the presence of students or employees of the district.  Employees who work exclusively outdoors means those individuals who do not spend any part of their work time indoors. 

Face Coverings

Beginning December 6, 2021, face coverings must be worn by all employees who have not provided proof of full vaccination status to the district.  Face coverings will be worn when employees are working indoors, in vehicles or other enclosed spaces.  Face coverings are not required to be worn when employees are: working alone in a room with floor to ceiling walls and a closed door; verifying identity for security purposes or eating/drinking; when an employee is wearing a respirator or facemask; or where the district can show that the use of a face covering is infeasible or creates a greater hazard.  The face covering must fully cover the employee’s nose and mouth; and be replaced when wet, soiled or damaged.

Reporting Requirements of the District

The district will report to OSHA: 

• Each work-related COVID-19 fatality within 8 hours of the employer learning about the fatality;
• Each work-related COVID-19 inpatient hospitalization within 24 hours of the employer learning about the inpatient hospitalization.

The district will report to individual employees or anyone having written authorized consent of the employee by the end of the next business day after the request is made:

• Documentation of any COVID-19 test results for that employee;
• The aggregate number of fully vaccinated employees at a workplace along with the total number of employees at that workplace.

The district will provide to the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or their designee:

• A copy of this policy, and the aggregate number of fully vaccinated employees at a workplace along with the total number of employees at that workplace, to be provided within 4 business hours of the request being made; and

All other records and supporting documents related to this policy by the end of the next business day of the request being made.

For additional information on COVID-19 vaccine efficacy, safety, and the benefits of being vaccinated, please consult the following document “Key Things to Know About COVID-19 Vaccines” https://www.cdc.gov/coronavirus/2019-ncov/vaccines/keythingstoknow.html

29 C.F.R. 1904.34(b)(1)(iv) prohibits the employer from discharging or in any manner discriminating against an employee for reporting a work-related injury or illness.

11(c) of the Occupational Safety and Health Act prohibits the employer from discriminating against an employee for exercising rights under, or as a result of actions that are required by, this policy.  11(c) also protects employees from retaliation by the employer for filing an occupational safety or health complaint, reporting a work-related injury or illness, or otherwise exercising any rights provided by the OSH Act. 

18 U.S.C. 1001and section 17(g) of the OSH Act provide for criminal penalties associated with knowingly supplying false statements or documentation in accordance with this policy.