As we continue to battle COVID-19, we continue to witness peaks and valleys in cases and deaths. With various reopening phases occurring across the country, taskforce leaders have addressed Congress and the nation, urging people to follow specific guidelines to protect Americans against further exposure to and spread of the coronavirus.
The guidelines include wearing a mask, adhering to social distancing, cleaning and disinfecting contaminated surfaces, and maintaining strict hand hygiene. They seem simple enough to follow. The decisions we make on a daily basis, and the recommendations we ignore, can have far-reaching consequences.
In dentistry, the ADA and the Centers for Disease Control and Prevention (CDC) have provided recommendations for resuming practicing during the reopening phases. These recommendations are a heightened version of the mandated regulations that we should already be implementing in all of our practices.
Standard precautions, such as the use of personal protective equipment (PPE) and barriers and care of the environment, should already be a part of your existing infection control programs under the umbrella of your Exposure Control Plan (ECP).
The Occupational Safety and Health Administration (OSHA) is an integral part of maintaining the safety of patients and workers in dental facilities with two main standards in place, the Bloodborne Pathogen Standard and the Hazard Communication Standard.
Employers must identify the biological, chemical, physical, and environmental dangers in their practice that may affect both patients and staff, meaning the standards require offices to develop an Occupational Exposure Plan. OSHA demands that you not only identify these exposures, but also have a policy in your practice that outlines how your specific practice will handle a situation if an exposure occurs.
Additional Dentistry Recommendations
After OSHA established the Bloodborne Pathogen Standard, the CDC acknowledged that other biological hazards exist that may affect not only healthcare workers, but their patients and the community, too.
The CDC and ADA have amplified mandated OSHA controls, or protection measures. They are the best scientific, evidence-based practices to prevent illness and to avoid exposure to any potential infectious diseases. It is so significant to adhere to the additional recommendations, inclusive of what is already mandated in your practice, to battle the relentless coronavirus.
Furthermore, platforms and healthcare management solutions like oneSOURCE can also assist your office in meeting these ever changing times by offering the most updated and comprehensive databases of instructions for use (IFUs) and manufacturer manuals required to comply with oversight agencies such as OSHA, CDC, ADA and more.
From dental curing lights to implants, oneSOURCE equips businesses with nearly 100,000 searchable catalog numbers, enabling practitioners to meet regulatory requirements with ease and keep patients and staff safe at all times.
Implementing an Occupational Exposure Plan
OSHA defines an exposure as “a specific occupational incident involving eye, mouth, other mucous membranes, non-intact skin, or parenteral contact with blood or other potentially infectious materials.”
Your Occupational Exposure Plan should identify potential hazards unique in your specific practice. Training needs to occur upon employment or introduction of new hazards, and these plans should be reviewed annually.
Training records must include training dates, the contents or a summary of the training session, the names and qualifications of the trainers, and the names and job titles of the trainees. All training records must be kept for three years from the date of the training.
If the employer ceases to do business, medical and training records must be transferred to the successor employer. If there is no successor employer, the employer must notify the director of the National Institute for Occupational Safety and Health (NIOSH) for instructions regarding the disposal of records. This must be done at least three months prior to disposing of any records.
All employees who are at risk of occupational exposure to bloodborne pathogens should receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. In addition, the training program should cover, at a minimum:
- A copy and explanation of the OSHA Bloodborne Pathogen Standard and Hazard Communication Standard
- An explanation of your office-specific Exposure Control Plan and how to obtain a copy
- An explanation of methods used to recognize tasks and other activities that may involve exposure to hazards, blood, and other potentially infectious material (OPIM), including what constitutes an exposure incident
- An explanation of the use and limitations of engineering controls, work practices, and PPE
- An explanation of the types, uses, location, donning and doffing, handling, decontamination, and disposal of PPE
- An explanation of the basis for PPE selection per task
- Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge
- Information on the appropriate action to take and persons to contact in an emergency involving blood or OPIM and/or hazard exposure
- An explanation of the steps to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available
- Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident
- An explanation of the signs and labels and/or color coding required by the standards and used at your facility
- An opportunity for interactive questions and answers with the person conducting the training session
Additionally, training materials for the facility should be kept in each employee’s private records and be made available when necessary to employees, medical professionals, or authorized oversight agencies.
Administration of Post-Exposure Evaluation and Follow-Up
If an exposure occurs, there needs to be a protocol in place for an efficient means of caring for that exposure. Administer first aid immediately to the person exposed, followed by communication with the employer that an exposure has occurred and the circumstances surrounding the incident.
A predetermined, licensed healthcare professional should be designated for treatment of post-exposure evaluations and follow-up. This licensed individual should be given a copy of your OSHA Bloodborne Pathogen Standard.
If an employee refuses to be treated following an occupational exposure, a declination form needs to be completed. The declination form should include the specifics of the incident. It also should note that professional evaluation was available and offered, and it then should be signed by the employee that he or she refused to seek evaluation or treatment.
The pre-designated healthcare professional evaluating an employee after an exposure incident should receive:
- A description of the employee’s job duties relevant to the exposure incident
- Routes and circumstances of the exposure
- If possible, the results of the individual’s blood test
- Relevant employee medical records, including vaccination status
Provide the employee with a copy of the evaluating healthcare professional’s written opinion within 15 days after completion of the evaluation.
Procedures for Evaluating the Circumstances Surrounding an Exposure Incident
When an exposure occurs, it is most important to review why it happened and how it could have been avoided. It is important to review the circumstances of all exposure incidents to determine:
- Engineering controls in use at the time
- Work practices followed
- A description of the device being used, including type and brand
- Protective equipment or clothing used at the time of the exposure, such as gloves and eye shields
- The location of the incident
- The procedure being performed when the incident occurred
- The employee’s training
Assign a person who will record all percutaneous injuries from contaminated sharps in a Sharps Injury Log. If revisions to your Exposure Control Plan are necessary, who has been designated to update changes or improve existing plans? Changes may include an evaluation of safer devices, adding employees to the exposure determination list, additional training, or a new way of thinking and/or performing a task. Communication is key whenever there is an injury or exposure in your office.
Remedies include posting information about the incident, without including personal medical information, to alert employees of a possible problem. Also, personnel should work together as an office by involving everyone’s input on how the dental practice can be made safer and healthier.
Remember, post-exposure evaluations and hepatitis B vaccinations must be made available to employees at no cost. Evaluations must be performed by a licensed physician or other appropriately licensed healthcare professional. Check with your employer, as some states require flu vaccinations as well. And, always check with your local and state departments of health and state boards for specific requirements of your state.
Have you been exposed?
Ms. O’Brien is a oneSOURCE consultant and owner and president of Office-Based Surgery Consultant. She also is a registered dental hygienist with more than 20 years of experience instructing on OSHA regulatory requirements as an outreach trainer. An OSHA Authorized Outreach Trainer, ICP, and office-based surgical consultant, she consults with leading hospitals, clinics, and dental and healthcare practices around the United States to help develop standard operating procedures necessary to achieve optimal infection control and compliance programs mandated by federal, state, and local officials.
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