Review and update exposure plan documents

Part 2 of a series outlining the contents of a written infection exposure control plan for your office.

The first part of the written exposure control plan (required for the dental office by OSHA) was reviewed in the January 2002 issue of RDH. It described the exposure determination, universal precautions, engineering and work practice controls, handwashing, handling contaminated sharps, work area restrictions, specimen handling and contaminated equipment. This issue will complete the plan.

Personal protective equipment (PPE): Indicate that PPE (e.g., gloves, masks, protective eyeglasses, protective clothing) will be provided at no cost to the employees, and that it will be chosen on the basis of anticipated exposure to blood and saliva. The PPE will be considered appropriate if it does not allow blood or saliva to reach employees' clothing, skin, eyes, mouth, and mucous membranes under normal conditions. List how the PPE will be provided to employees (e.g., where they are stored and who will supply and re-stock), and list what procedures require gloves, masks, protective eyeglasses, protective clothing, etc.

State that all PPE will be cleaned, laundered, disposed of and replaced, when necessary, by the employer at no cost to the employee. Also indicate that PPE will be removed immediately if penetrated, and that PPE will not be worn out of the work area (define the work area and describe where the PPE is to placed when removed). State that gloves will not be washed or decontaminated for reuse, and will be replaced as soon as possible when they are torn, punctured, or otherwise compromised. Utility gloves may be decontaminated for reuse (provided the integrity is not compromised), and will be discarded if they are cracked, torn, peeling, punctured, or otherwise compromised.

Housekeeping: List the schedule when specific work areas will be decontaminated (e.g., operatory 1: after every patient), and indicate if protective surface covers will be used, and where and when they will be used. Describe how and when any receptacles (e.g., pans, bins, trays) will be decontaminated, and that broken glass will not be picked up with the hands. Describe how broken glass will be handled (e.g., with tongs).

Regulated waste disposal: Indicate that all contaminated sharps will be discarded as soon as feasible in sharps containers, and state where these containers will be located. Also describe procedures for discarding non-sharp regulated waste (e.g., non-sharp solids saturated or caked with blood or saliva, extracted teeth, liquid blood, or saliva).

Laundry procedures: State that contaminated laundry will be handled as little as possible by persons wearing PPE, and that it will be placed in appropriately marked bags where it is used. All employees who handle laundry will use appropriate PPE. Indicate where the laundry will be cleaned (e.g., off-site or in-house).

Hepatitis B vaccine: Indicate that all employees having potential for exposure to blood or saliva will be offered the hepatitis B vaccination series at no cost to them within 10 working days of their initial assignment (unless they already have been vaccinated or wish to submit to antibody testing to show sufficient immunity). State that employees who refuse the vaccination offer will sign the appropriate waiver described in the OSHA standard. Indicate who will administer the vaccine and who has the responsibility for assuring that the vaccination series is offered and the waivers are signed.

Postexposure evaluation and follow-up: List who has the responsibility to maintain records of exposure incidents and to whom such incidents should be reported. State that all exposed employees will be offered an evaluation and follow-up that includes:

  • Documentation of the route of exposure and the circumstances related to the incident
  • The identification (if possible) of the source individual (e.g., the patient) involved and the testing (with consent) for HIV/HBV status
  • Informing the exposed individual of the results of testing and of the related confidentiality laws concerning the identity and infectivity of the source individual
  • Offering the exposed individual serological testing for HIV/HBV/HCV status
  • Preserving the blood sample for 90 days to allow time for the exposed individual to decide if the blood should be tested for HIV status
  • Offering of postexposure prophylaxis
  • Appropriate counseling concerning the precautions to take during the period after the exposure incident
  • Information given to the exposed individual on what illnesses to be alert for and to report any related experiences to appropriate persons.

Indicate who will be responsible for ensuring that this policy is carried out.

Interaction with health-care professionals: Indicate that written opinions will be obtained from health-care professionals who evaluate employees in the office when the employee is sent to obtain the hepatitis vaccination series and whenever the employee is sent for a postexposure evaluation and follow-up. State that health-care professionals shall only indicate whether the hepatitis B vaccine is indicated and if the employee has received the vaccine, or for evaluation following an exposure incident; that the employee has been informed of the results of the evaluation; and that the employee has been told about any medical conditions resulting from the exposure.

Training: State that training for all employees will be conducted prior to their initial assignment to tasks where exposure may occur, and that training will be updated at least annually.

The training will include:

  • An explanation of the OSHA bloodborne pathogens standard
  • Epidemiology and symptoms of bloodborne diseases
  • Modes of transmission of bloodborne pathogens
  • All aspects of the exposure control plan
  • Procedures that might cause exposure to blood or saliva
  • Control methods which will be used to control exposure
  • PPE available and who should be contacted after an exposure
  • The postexposure evaluation and follow-up procedures
  • The nature of the signs and labels used in the office
  • The hepatitis B vaccine program.

Describe what type of training will be provided to the employees (e.g., video tapes, lectures) and who is responsible for conducting the training. Also describe where the training materials are located and that refresher training will be provided at least annually.

Needlestick prevention: Include a description of how new safety devices that may reduce the chances of sharps injuries will be identified and considered annually for adoption in the office. Describe the methods used to evaluate such devices (including persons who are potentially exposed to injuries) and the results of the evaluations. Also state the justification as to why a device was or was not selected for use.

Recordkeeping: Indicate that all records required by the bloodborne pathogens standard will be maintained, and indicate who will be responsible for maintaining such records.

It is important to remember that a written exposure control plan for the office is required by OSHA and must be updated at least annually. Further details about this plan can be obtained at the following Web site: www.osha-slc.gov/OshStd_data/1910_1030.html.

Chris Miller, PhD, is professor of oral microbiology and executive associate dean at the Indiana University School of Dentistry.

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