A periodic check of the office`s infection control program helps fight complacency and reminds everyone of the continued importance of preventing microbe spread. This periodic checkup also helps assure that any new members of the office team are performing appropriately, and it serves as an update on compliance with any new procedures that have been instituted. A checklist approach to conducting these reviews on recordkeeping, training, and hepatitis B vaccination is presented here with further areas to be presented in future issues of RDH.
- A written Exposure Control Plan for the office is in place, is available to all office personnel, and is updated at least annually.
- The Exposure Control Plan contains the descriptions of:
- The exposure determinations.
- The schedule and methods of implementation of the methods of compliance.
- The hepatitis B vaccination program (including, for example, how new employees are evaluated for the vaccine).
- The post-exposure medical evaluation program (including, for example, what is to be done after an employee is exposed to blood or saliva).
- How biohazards are to be communicated to employees in the office.
- The recordkeeping system documenting compliance with the OSHA Bloodborne Pathogens Standard (including, for example, the employee training and medical records described below).
- Procedures for evaluating the circumstances surrounding an exposure incident.
n A copy of the OSHA Bloodborne Pathogens Standard is available to all employees.
n Records of employee training on bloodborne diseases and infection control are kept for three years and include: names and job titles of all trainees; dates training received; name and qualifications of the trainer; and a summary of the content of the training.
n Confidential medical records of employees are kept for the duration of employment plus 30 years. These records include:
- Name and Social Security number.
- Copy of employee`s hepatitis B vaccination status, including dates of all of the hepatitis B vaccinations and any medical records relative to the employee`s ability to receive the vaccination.
- Any signed vaccination refusal statement from the employee.
- Reports documenting employee exposure incidents.
- The results of testing following an exposure incident.
- The written opinion from the health care professional (physician, for example) who evaluated the employee. The professional indicates that the employee was evaluated and informed of any medical conditions resulting from the exposure that require further evaluations or treatment.
- The list of documents given to the health care professional evaluating each exposure incident.
n Records are maintained describing the treatment and/or transport of regulated waste that may be required by local or state agencies. If the waste is treated in the office before disposal, the records may include a description of the waste treated, the dates and methods of treatment used, and spore-testing records of any sterilizers used to treat the waste.
Waste transport records may include a manifest from the waste hauler indicating the EPA authority of the hauler, the waste pick-up dates, as well as where the waste was transported and finally treated. Records needed may vary depending on your locale.
n Records of spore-testing for each sterilizer in the office are maintained as may be required by local or state agencies. Such records may include dates of tests, results of tests, and identification of who performed the tests. The nature of the records needed may vary depending on your locale.
n New employees receive initial training on the basics of bloodborne diseases before they perform tasks that may result in exposure to a patient`s blood or saliva. This training is at no charge to the employees. It is offered at a convenient time, at an appropriate educational level, and in an appropriate language. This training is to include:
- The information in the office`s Exposure Control Plan.
- A description of the cause, symptoms, epidemiology, spread, and prevention of bloodborne diseases.
- The selection, use, limitation, and management of equipment or supplies used to prevent microbe spread in the office.
- What to do if exposure to blood or saliva occurs.
- An explanation of the color code or signage used to identify biohazards in the office.
- An opportunity for the trainees to have their questions answered.
- Within 10 days of employment, new employees receive training on the hepatitis B vaccine (description, safety, efficacy, route of administration, and benefits of the vaccination).
- All employees receive bloodborne disease and infection control update training annually, as well as when changes occur in disease prevention laws, procedures, equipment, or supplies.
Hepatitis B vaccination
- Within 10 days of employment and after receiving the hepatitis B vaccination training, all new employees are medically evaluated for hepatitis B vaccination and, when indicated, are offered the hepatitis B vaccination series free of charge.
- The health care professional evaluating employees for hepatitis B vaccination provides written documentation to the dentist or employer on whether an employee has been evaluated and if the employee is receiving the vaccination series. This documentation is to be provided within 15 days of the evaluation and is to be kept in the employee`s medical records.
- Employees who decline vaccination read and sign the required OSHA "Vaccine Declination" statement. The signed statement is kept in the employee`s medical records.
In summary, these checklists discuss only documentation, recordkeeping, and vaccinations. Checklists for post-exposure medical evaluations, instrument processing, surface asepsis, aseptic techniques, management of regulated waste, and laboratory and radiographic asepsis will be included in future issues.
Chris Miller is director of Infection Control Research and Services and professor of oral biology at Indiana University.