Update your exposure control plan documents

Two-part series outlines the contents of a written infection exposure control plan for your office.

The written exposure control plan for your office needs to be reviewed and updated at least annually. Consider starting off the New Year with the required annual review of your plan. One key rule of the bloodborne pathogens standard is the requirement for each dental office to have a written exposure control plan that is made available to the office employees, and the plan is to be reviewed or updated annually. The plan describes how exposure to bloodborne pathogens will be eliminated or minimized.

The general contents of the plan will be described below and in next month's issue of RDH. For details about the plan, see the OSHA Bloodborne Pathogens Standard at http://www.osha-slc.gov/OshStd_data/1910_ 1030.html. (Include hyphen in this URL.)

Exposure determination
An exposure determination identifies which employees may incur occupational exposure to blood or saliva. This determination is made without regard to the use of personal protective barriers. List all job classifications in which any employee may be expected to incur occupational exposure, regardless of frequency. These would include hygienists and assistants.

Also, list job classifications in which some employees may have any occupational exposure, such as receptionists and office managers. Since not all employees in the latter category would be expected to incur exposure to blood or saliva, tasks, or procedures that would cause these employees to have occupational exposure also are required to be listed. This will establish a clear understanding of which employees are considered to have occupational exposure.

Implementation schedule and methodology
Universal precautions: Indicate that universal precautions will be observed to prevent contact with blood or saliva, and that all blood and saliva will be considered to be infectious regardless of the perceived status of the patients.

Indicate that engineering controls (for example, sharps containers or surface covers) and work-practice controls (for example, handling needles safely) will be used to eliminate or minimize exposure to body fluids. List those controls used in your office and indicate that those controls will be maintained on a regular schedule and reviewed for effectiveness. Establish the schedule (for example, daily, once a week, etc.), and state who will be responsible for reviewing effectiveness.

Handwashing: State that handwashing facilities are available to those who may experience exposure, and indicate where the sinks are located. Indicate when handwashing should occur, and state that employees are to remove their gloves and wash their hands and any other potentially contaminated skin or mucous membranes as soon as feasible. The areas should be washed or flushed with water as appropriate as soon as feasible following contact.

Handling contaminated sharps: Indicate what are considered as contaminated sharps and describe how they will be handled. Describe those situations in which used needles will be recapped before disposal and describe how the recapping will be accomplished safely. Describe the sharps containers to be used (for example, rigid, puncture-resistant, closable, leak-proof on the sides and bottom, properly labeled) and where they will be placed in the office (where sharps are used or found).

Indicate that the containers will be closed before storage or transport, and identify who will be responsible for managing the containers (for example, replacing them when full, sterilizing them, labeling them before disposal).

Document annual consideration of any new commercially-available devices for reducing sharps injuries (for example, safety needles). This includes describing how such medical devices are identified and evaluated for possible use in the office.

Also describe the methods used to evaluate the device, who is to be involved in the evaluation, the results of the evaluations, and the justification as to why the device was or was not selected for use.

Work area restrictions: Indicate that employees are not to eat, drink, smoke, apply cosmetics or lip balm, handle contact lenses, or store foods in areas where blood and saliva contamination may occur. Identify these areas. Describe procedures and products that will be used to minimize the spraying or spattering of blood or saliva (for example, rubber dam, high-volume evacuation, pre-procedure mouth rinsing, saliva-ejector).

Specimens: Describe how specimens of tissue, teeth, or body fluids are to be contained before handling, processing, storage, transport or shipping (for example, closable, leak-proof on the sides and bottom, properly labeled, puncture-resistant when necessary). State that if the outside of the primary container is contaminated, it is to be placed in a second container that prevents leakage.

Contaminated equipment: Indicate that equipment that has become contaminated with blood or saliva is to be examined prior to servicing or shipping, and is to be decontaminated as necessary if feasible. Identify equipment that cannot be decontaminated prior to servicing or shipping, and describe how the non-decontaminated portions are identified so that precautions can be taken by those who may come in contact with the equipment.

In the next issue, we will continue these considerations for the general content of the exposure control plan.

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

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