Review of Bloodborne Pathogens Standard clarifies OSHAs expectations of dental offices

Feb. 1, 1998
While everyone agrees that disease prevention is important, several agencies have further assured the performance of infection-control procedures by formulating specific regulations or recommendations. While most of these rules or guidelines have been known for several years, it may be important to periodically review them to combat complacency and double-check compliance. This month`s column, as well as next month`s, will review the OHSA Bloodborne Patho-gens Standard.

Chris Miller, PHD

While everyone agrees that disease prevention is important, several agencies have further assured the performance of infection-control procedures by formulating specific regulations or recommendations. While most of these rules or guidelines have been known for several years, it may be important to periodically review them to combat complacency and double-check compliance. This month`s column, as well as next month`s, will review the OHSA Bloodborne Patho-gens Standard.

The Occupational Safety and Health Administration (OSHA) developed this standard that became effective nationwide in 1992. In 1992, OSHA also published an interpretation of the standard for dentistry, "Controlling Occupational Exposure to Bloodborne Pathogens in Dentistry" (OSHA publication No. 3129). You are encouraged to read these publications for a clear understanding of the details. Additionally, the standard itself requires all dental offices to make a copy of the standard available to the employees.

OSHA is charged by Congress to protect the workers of America. In this light, this OSHA standard describes what employers are to do to limit occupational exposure of their employees to blood and other potentially infectious body fluids (saliva, for example). Thus, the purpose of the standard is to prevent the occurrence of occupationally related bloodborne diseases, such as HIV disease and hepatitis. In dentistry, it covers all employees who could be exposed to blood or saliva (even one time) during the performance of their job duties.

The major sections of the standard include:

- Exposure-control plan - Each office is to have a written exposure-control plan that identifies tasks, procedures and job classifications where occupational exposure occurs (without regard to the use of protective barriers). This plan is to contain a schedule of how and when the provisions of the standard are to be implemented.

The exposure-control plan will include schedules and methods for communication of biohazards to employees (training), hepatitis B vaccination, post-exposure evaluation and follow-up, record-keeping, and infection-control procedures such as engineering and work-practice controls. Additionally, it covers the use of gloves, mask, gowns, eyewear, decontamination procedures and waste management. Also, the plan describes procedures for evaluating the circumstances of an exposure incident. The plan is to be made available to the employees and updated at least annually. Sample plans are available from local OSHA offices or the Office Safety and Sterilization Procedures (OSAP) Research Foun-dation [(800) 298-OSAP].

- Universal precautions - The standard mandates universal precautions (treating all body fluids as if infectious). It emphasizes the use of engineering and work-practice controls to try to reduce the level of contaminants that may be involved in an exposure. Examples of engineering controls in dentistry are high-volume evacuation, rubber dams and sharps containers. Examples of work-practice controls include hand-washing, handling sharps carefully, properly containing regulated waste, and not eating, drinking or applying cosmetics or contacts where occupational exposure to body fluids may occur.

- Personal protective equipment - Employers are to purchase and provide, maintain, ensure use of, launder, and discard personal protective equipment (gloves, mask, protective eyewear, and protective clothing) for covered employees. This protective equipment is to be worn when there is a chance that an employee may come into contact with blood or saliva. Appropriate personal protective equipment must not allow blood or saliva to pass through to clothing, skin, or mucous membranes.

Alternative equipment is to be provided if an employee has a reaction (allergy) to the product usually provided. Protective eyewear is to provide protection to the sides of the eyes (side shields for eyeglasses or curved face shields). Disposable gloves are to be replaced if torn during a procedure and are not to be washed and reused on another patient. Utility gloves are to be decontaminated after use. Protective clothing may be disposable or reusable. Reusable clothing of cotton or cotton/polyester usually is satisfactory for routine dental procedures.

- Decontamination of surfaces - The standard requires a written schedule for cleaning the office areas that may become contaminated with blood or saliva. The description includes the methods used to decontaminate these areas, as well as the cleaning procedure used.

Contaminated reusable containers are to be cleaned and disinfected when visibly soiled. Plastic covers that are used to prevent contamination of surfaces are to be replaced when contaminated. Equipment to be shipped for repair is to be decontaminated or labeled as a biohazard, indicating which parts could not be decontaminated.

- Waste management - Regulated waste is liquid or semi-liquid body fluid; items contaminated with body fluid that would release this material in a liquid or semi-liquid state when compressed; items that are caked with dried body fluid and are capable of releasing this material during handling; contaminated sharps; and pathological and microbiological wastes containing body fluid.

Disposable sharps (anything that can puncture the skin) are to be placed in containers that are closable, puncture-resistant, leak-proof and colored red or labeled for disposal. These containers are to be located as close as possible to where sharps are used and found. They are to be maintained upright, not to be over-filled, and are to be closed upon transport. Needles are not to be re-capped by hand nor broken or sheared prior to disposal.

Other non-sharp and non-liquid regulated wastes (such as items saturated or caked with blood or saliva) are to be placed in closable leak-proof bags or containers that are colored red or labeled. A secondary container that also is closable, leak-proof, and coded is necessary for containers contaminated on the outside. Local laws govern how regulated waste may be discarded.

- Laundry - Contaminated laundry is to be handled as little as possible and only when using personal protective equipment. It should not be sorted in clinical areas. Laundering of contaminated protective clothing is the responsibility of the employer and can be accomplished through the use of a washer and dryer in the office or contracting with a commercial laundry. Contaminated laundry in the office is to be placed in containers that are red or labeled with the biohazard symbol.

Chris Miller is director of Infection Control Research and Services and professor of oral biology at Indiana University.