The Standard requires that each office have a written exposure control plan that describes how occupational exposure to bloodborne pathogens will be eliminated or minimized in the office.
Chris Miller, PhD
Having a written plan that describes the office`s infection-control policies and procedures is important to all. It helps in the training of new employees. It serves as the reference for procedures in the office. It helps when reinforcement of policies is needed for continuing staff, and it provides compliance with the OSHA Bloodborne Pathogens Standard. This standard requires that each office have a written Exposure Control Plan that describes how occupational exposure to bloodborne pathogens will be eliminated or minimized in the office in accordance to the Bloodborne Pathogens Standard.
A model Exposure Control Plan (ECP) from OSHA is summarized below. Details should be obtained directly from OSHA (www.osha-slc.gov/OshDoc/Directive_data/CPL_2-2_44D.html#APPENDIXD).
Policy - Describe the name and location of the dental office, indicate the office commitment to the Bloodborne Pathogens Standard, and list the major sections of the ECP.
Program administration - List the names, location and phone numbers of the persons responsible for preparing the ECP. Also list those who are responsible for. maintaining and updating the ECP annually; providing and maintaining adequate supplies and sizes of personal protective equipment (PPE) and engineering controls; assuring that all medical actions (vaccination, post-exposure follow-up) are performed and records maintained; training, documentation of training, and making the ECP available to all employees.
Employee exposure determination -List all job classifications in the office (e.g., hygienist) in which all employees in the classification have occupational exposure. List all job classifications in which some employees have occupational exposure and describe the tasks that can lead to exposure. Describe how the rules of standard will be met for part-time, temporary, contract, and other employees.
Methods of implementation and control -
- Universal precautions: Indicate that all employees will follow universal precautions.
- ECP: State that the employees will receive an ECP during their initial training, plus an annually updated ECP.
- Engineering controls and work practices: Describe what engineering controls (e.g., sharps containers, rubber dams) and work practices (e.g., safe needle recapping) will be used to prevent or minimize exposures and how associated products will be maintained and used in a safe manner. Also describe how new engineering controls (e.g., any new safety needles) and work practices will be evaluated for possible use in the office.
- PPE: Give the types of PPE available; where they are located and how they are obtained; how they are to be used; and how they are to be discarded.
- Housekeeping and decontamination: Describe how regulated wastes (e.g., sharps, blood-saturated gauze, extracted teeth) will be handled. Describe the waste containers used, and indicate how those containers will be labeled or color-coded as a biohazard and how they will be moved within the office. Describe how and when contaminated surfaces and items will be cleaned and disinfected. Describe what items may be covered to prevent contamination and when those covers will be changed. Indicate that broken glass will be picked up in a safe manner (tongs, brush, and dust pan, for example).
Y Laundry: Indicate how contaminated laundry will be handled and who will do the laundering (office personnel or medical laundry service).
Y Labels: Describe what labeling (biohazard symbols, color-coding) will be used for sharps containers, laundry, or contaminated equipment being shipped for repair. Indicate who should be contacted if items are not properly labeled.
Hepatitis B vaccination ? Indicate who will provide the required vaccination training to new employees within 10 days of initial employment and describe the mechanism for vaccination (where, when, no cost to employee, post-vaccination testing). Indicate that vaccination is encouraged unless the employee has previously received the vaccine series; antibody testing reveals immunity; or medical evaluation shows that vaccination is contraindicated. Indicate that an employee who refuses vaccination may receive it at a later date at no cost, if desired, but must sign the vaccination declination statement.
Post-exposure evaluation and follow-up ? Indicate who to contact upon exposure and state that a confidential medical evaluation and follow-up will be provided. Indicate what licensed health-care professional (physician) will provide this evaluation and describe the procedures to be followed. For example, document and describe the exposure incident; identify the source individual, obtain consent and have individual tested for HIV, HCV, and HBV status; document that the test results will be provided to the evaluating physician; assure that exposed employee is informed of all test results and is aware of confidentiality laws; obtain consent and test the employee?s blood for HIV and HBV status.
Administration of vaccinations and medical evaluation ? Indicate who will ensure that the physician evaluating an exposure will receive a description of the employee?s job duties, routes, and circumstances of exposure, results of the source individuals? blood tests, and relevant employee medical records. Also indicate who will be responsible for providing the employee with a copy of the evaluating physician?s written opinion within 15 days after completion of the evaluation.
Review of exposure incidents ? Describe who will review the circumstances surrounding an exposure incident. Describe what will be considered in this review and who will make sure that any identified changes in procedures or equipment will be implemented and added to the ECP.
Employee training ? Indicate that all employees who have occupational exposure receive training on the epidemiology, symptoms, and transmission of bloodborne diseases, in addition to training on the methods described in the standard and in the ECP. State that a copy of the standard is available in the office and give its location. Also describe who will provide the training and give a brief description of the trainer?s qualifications. Indicate where training materials and a copy of the ECP and the OSHA standard will be available.
Recordkeeping ? Indicate that training records will be completed for each employee and kept for three years. Indicate that confidential medical records are maintained for each employee covered under the standard for the duration of employment plus 30 years. Indicate who is responsible for maintaining those confidential records and where they are located. Indicate that employee medical records are provided upon request of the employee or an authorized person (with written consent of the employee) within 15 working days. List to whom such requests should be made.
Chris Miller, PhD, is professor of oral microbiology and associate dean at the Indiana University School of Dentistry.
