OSHA. MANUAL A benefit provided by the Wisconsin Dental Association to member dentists IN THE DENTAL OFFICE BLOODBORNE PATHOGENS MANUAL

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1 OSHA BLOODBORNE PATHOGENS MANUAL IN THE DENTAL OFFICE PARTIALLY UNDERWRITTEN BY MANUAL A benefit provided by the Wisconsin Dental Association to member dentists WDA updates made in 2008 Also available online at WDA.org

2 OSHA BLOODBORNE PATHOGENS STANDARD EXPOSURE CONTROL PLAN The following Exposure Control Plan has been developed and updated in accordance with the OSHA BLOODBORNE PATHOGENS STANDARD, 29 CFR FOR DENTAL OFFICE USE Employer(s) Name(s) Dental Office/Practice/Facility Name Address Assigned Staff Person(s) Date(s) Most Recently Updated OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA i

3 TABLE OF CONTENTS WDA DISCLAIMER EXPOSURE CONTROL PLAN, PURPOSE AND ADMINISTRATION INSTRUCTIONS FOR EXPOSURE CONTROL PLAN USE EXPOSURE DETERMINATION Exposure Determination Form Sample For use in this dental office METHODS OF IMPLEMENTATION AND CONTROL Universal Precautions Exposure Control Plan Employee Rights Employer Responsibilities Engineering and Work Practice Controls A. Sharps Containers B. Other Engineering Controls C. Program to Select and Evaluate Safer Medical Devices D. Needlestick Safety and Prevention Act Form Sample For Use in this Dental Office D. Washing Facilities E. Disposable Sharps F. Other Contaminated Sharps G. Reusable Sharps H. Work Area Restrictions I. Impressions/Appliances/Equipment etc Personal Protective Equipment A. Gloves B. Eye and Face Protection C. Personal Protective Clothing D. Resuscitation Masks or Devices E. Other Protective Clothing/Devices F. Disposal, Storage, Cleaning and Laundering Housekeeping A. General Housekeeping B. Clinical Area Decontamination C. Laundry Procedures Regulated Waste Definition of Regulated Waste OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA ii

4 TABLE OF CONTENTS HEPATITIS B VACCINATION AND ANTIBODY TESTING Hepatitis B Vaccine Declination Form POST-EXPOSURE EVALUATION AND FOLLOW-UP Occupational Exposure Incident Report Form Sample For Use in this Dental Office COMMUNICATION OF HAZARDS TO EMPLOYEES AND TRAINING Labels and Signs Information and Training OSHA Bloodborne Pathogens Standard Training Record Sample For Use in this Dental Office RECORD KEEPING EVALUATION AND REVIEW OF EXPOSURE CONTROL PLAN APPENDIX (Reference Materials) a1 Employer Reference Pages a1-12 Employer Liability a1-3 Employer Rights at the Time of an OSHA Inspection a4 Employer Frequently Asked Questions a5 Useful Definitions a6 Web Sites for Referential Documents/Other Helpful Contacts a7 Needle Safety Amendments a8-9 State and Federal Poster Requirements a10-12 WDA WEB SITE MEMBERSHIP SERVICES SUMMARY a13 a14 OSHA Bloodborne Pathogens Manual can be accessed from the WDA Web site, WDA updates made in 2008 OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA iii

5 WDA DISCLAIMER This OSHA Exposure Control Plan has been developed by the Wisconsin Dental Association, in conjunction with Dr. Elise Sampson (Marquette University School of Dentistry), and is provided for informational purposes only. It should not be construed or understood as legal advice on any specific issue or issues. The contents of this publication are general in nature and cannot be relied upon for guidance in specific situations. You (the employer) should consult with your attorney to determine how matters discussed in this plan may relate to your practice or situation. THE WISCONSIN DENTAL ASSOCIATION, INC. MAKES NO REPRESENTATION OR WARRANTY, EITHER EXPRESSED OR IMPLIED, WITH RESPECT TO THIS PLAN AND DOES HEREBY EXPRESSLY DISCLAIM ANY AND ALL WARRANTIES AS TO THE ACCURACY OF THE CONTENTS OF THIS MATERIAL, ITS APPLICABILITY TO ANY SPECIFIC CIRCUMSTANCES OR SITUATION, OR ITS APPLICABILITY OR VALIDITY IN ANY PARTICULAR JURISDICTION. The Wisconsin Dental Association, Inc. expressly disclaims any and all: i) responsibility for opinion(s) expressed by the author and any inaccuracies, errors or omissions contained in these materials; ii) obligation to revise or update these materials at anytime in the future. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 1

6 EXPOSURE CONTROL PLAN, PURPOSE AND ADMINISTRATION PURPOSE (Dental Office/Practice/Facility Name) is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following Exposure Control Plan is provided to eliminate or minimize occupational exposures to bloodborne pathogens in accordance with OSHA Standard 29 CFR , Occupational Exposure to Bloodborne Pathogens. The Exposure Control Plan is a key document to assist this dental office/practice/facility in implementing and ensuring compliance with The Standard, thereby protecting our employees. ADMINISTRATION Directions: The spaces below are to be completed by either the employer or assigned staff person. is in charge of the implementation of this Exposure Control Plan. will maintain, review, and update the Exposure Control Plan at least annually, and whenever necessary to include new or modified tasks and procedures. will ensure that those employees who are determined to have occupational exposure to blood or other potentially infectious materials will comply with the procedures and work practices outlined in this Exposure Control Plan. will maintain and provide all necessary personal protective equipment, engineering controls (e.g., sharps containers), labels, and red bags as required by the Standard. will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. will ensure that all medical actions required are performed and that appropriate employee health and OSHA records are maintained. will conduct training, will maintain documentation of training and will provide the written Exposure Control Plan available to employees. will provide the written Exposure Control Plan to OSHA, and NIOSH representatives. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 2

7 INSTRUCTIONS FOR EXPOSURE CONTROL PLAN USE PLEASE READ CAREFULLY! CHECKBOXES The authors strongly recommend that the following individuals THE EMPLOYER(S) The person(s) ultimately responsible for assuring full compliance of the requirements of the Bloodborne Pathogens Standards. AND THE ASSIGNED STAFF PERSON(S) The person(s) delegated to implement portions of this Exposure Control Plan. read each statement very carefully, before placing a checkmark in the boxes provided. It is essential that you are certain the procedure indicated in each statement is being followed in your dental office/practice/facility. TO ENSURE COMPLIANCE IT IS STRONGLY RECOMMENDED THAT YOU PROVIDE STATEMENTS IN THE SPACES GIVEN AND CHECK EACH BOX THAT APPROPRIATELY DESCRIBES YOUR OFFICE'S PRACTICES. Please be honest and DO NOT check the boxes that do not reflect your office policies, procedures and standards. It is imperative, however; that by evaluating the boxes left unchecked that your dental office/practice/facility take steps to be able to check all boxes and ultimately come into full compliance with all portions of the plan. EXPOSURE CONTROL PLAN (ECP) SPACES There are multiple spaces that must be filled in with the name(s) of the employer(s) and/or assigned staff person(s). (These spaces must be filled in with the name(s) of the appropriate person(s) in your office/practice/facility.) ECP AVAILABILITY TO EMPLOYEES Once reviewed by the employer(s) and assigned staff person(s) this Exposure Control Plan shall be made available to employees in this dental office/practice/facility who are at risk of exposure to blood or other potentially infectious materials. ECP FORMS All forms are located within its corresponding section (e.g. Needlestick Safety and Prevention form is in the Needlestick Safety and Prevention section). Sample forms demonstrate the correct way to complete each form. Original forms are provided for the dental office/practice/facility to duplicate, complete and update when needed. APPENDIX Contains materials that are intended to supplement the contents of this manual. These materials are not part of the OSHA exposure control plan.the appendix is provided for additional information that might assist in clarifying procedures, or which may provide additional informational resources, as well as offer dental specific recommendations. This material is very useful and should be read and utilized accordingly. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 3

8 EXPOSURE DETERMINATION DEFINITION OSHA requires employers to perform an exposure determination to identify which employees may incur occupational exposure to blood and/or other potentially infectious materials. The exposure determination is made without regard to the use of personal protective equipment. Employees are considered to be at risk for exposure even if they wear personal protective equipment. An exposure determination has been developed for this dental office/practice/facility by listing all job classifications in which all employees may be expected to incur occupational exposure, regardless of frequency. EMPLOYER PAGE ATTENTION OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 4

9 EXPOSURE DETERMINATION FORM Dental Office/Practice/Facility Name: Address: Dr. Doe Dental 000 Apple Street Any Town, USA Dr. John Doe and Dr. John Smith Employer Name(s): must acknowledge their responsibility to provide all employees who perform tasks which could potentially place them at risk for occupational exposure to blood and/or other potentially infectious materials with full protection as stated in the OSHA Bloodborne Pathogens Standard 29 CFR part FORM 1s This exposure determination has been made without regard to the use of personal protective equipment. Dentists Dental Hygienists Lab Technicians/Other Receptionist JOB CLASSIFICATION List all job classifications in which employees have occupational exposure in this office/practice/facility Dental Assistants Dental Intern* List job classifications in which some, not all, employees, have occupational exposure in this office/practice/facility TASKS AND PROCEDURES IN WHICH OCCUPATIONAL EXPOSURE WILL OCCUR Operatory cleanup procedures including cleaning and processing instruments, disinfection of all contaminated surfaces and replacement of paper and plastic drapes.these duties are performed by receptionist when dental assistant is on vacation. SAMPLE * If this person is an unpaid student he/she is not covered by the OSH Act (OSHA). However, for liability purposes, it is wise to include them in your program. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 5

10 EXPOSURE DETERMINATION FORM For use in this dental office/practice/facility Dental Office/Practice/Facility Name: Address: Employer Name(s): must acknowledge their responsibility to provide all employees who perform tasks which could potentially place them at risk for occupational exposure to blood and/or other potentially infectious materials with full protection as stated in the OSHA Bloodborne Pathogens Standard 29 CFR part This exposure determination has been made without regard to the use of personal protective equipment. FORM 1 List all job classifications in which employees have occupational exposure in this office/practice/facility FOR USE IN OFFICE List job classifications in which some, not all, employees, have occupational exposure in this office/practice/facility JOB CLASSIFICATION TASKS AND PROCEDURES IN WHICH OCCUPATIONAL EXPOSURE WILL OCCUR OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 6

11 METHODS OF IMPLEMENTATION AND CONTROL UNIVERSAL PRECAUTIONS OSHA Definition Universal Precautions is an approach to infection control all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, HCV and other bloodborne pathogens. In this Dental Office/Practice/Facility, since medical history and examination cannot reliably identify all patients with Hepatitis B, C, HIV infection and/or other bloodborne pathogens, blood and body fluid precautions are consistently used for all patients and when handling contaminated instruments, equipment, appliances, waste (regulated and other) and laundry. EXPOSURE CONTROL PLAN EMPLOYEE RIGHTS In this Dental Office/Practice/Facility: Employees covered by the Bloodborne Pathogens Standard receive an explanation of this Exposure Control Plan during their initial training session. This Exposure Control Plan is reviewed in employee s annual training. Employees have an opportunity to review this plan at any time during their work shifts by contacting (Name of assigned staff person) If requested, I/we, the employer, will provide an employee with a written copy of this Exposure Control Plan free of charge and within 15 days of the request. EMPLOYER RESPONSIBILITIES Directions: The spaces below are to be completed by either the employer or assigned staff person. EMPLOYER PAGE ATTENTION will review and update the Exposure Control Plan on annual basis. Annual update of documentation will also include an assessment of technology changes that can reduce exposures. will review and update the Exposure Control Plan more frequently, if necessary, to reflect any new or modified tasks and procedures. will review and update the Exposure Control Plan to reflect new or revised employee positions with occupational exposure. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 7

12 ENGINEERING AND WORK PRACTICE CONTROLS In this Dental Office/Practice/Facility: Engineering and work practice controls are utilized to eliminate or minimize exposure of employees as follows: A. SHARPS CONTAINERS Sharps containers are closeable, labeled with the BIOHAZARD symbol (see page 29), puncture resistant, leak proof on the sides and bottom and designed so that employees cannot reach into the opening and be injured by the contents. Directions: Please complete spaces below with the name of the appropriate assigned staff person. Please be sure the name corresponds with the statement. will ensure that sharps containers are inspected according to the schedule listed below. They are inspected: daily weekly Other: (Please specify) will ensure that when filled to the required safety level, the sharps containers are closed, made ready for pick-up, transported or mailed to an appropriate storage site and replaced. Storage site: room # REGULATED WASTE SERVICE Name of Waste Service: Address: Phone: Pick up Schedule: / / / / / / / / / / / / / / / / B. OTHER ENGINEERING CONTROLS Whenever possible, procedures are conducted in a manner which minimizes splashing, spraying, splattering and generation of droplets of blood or other potential infectious materials by appropriate use of: Rubber dams High volume suction Saliva ejectors Other: (Please Specify) OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 8

13 ENGINEERING AND WORK PRACTICE CONTROLS CONTINUED In this Dental Office/Practice/Facility: C. PROGRAM TO SELECT AND EVALUATE SAFER MEDICAL DEVICES The revision of OSHA Bloodborne Pathogens Standard Needlestick Safety and Prevention Act (PL ) requires employers to identify and make use of effective and safer medical devices for dental offices (this largely refers to the review of safer needles or injection devices used in providing dental care) with the intention of reducing or eliminating worker exposure. Several sources of information are available for identifying and evaluating the appropriateness of new devices with engineering safety features. These include, but are not limited to, searching the Internet, reviewing dental and other literature and reviewing new products at professional meetings. This Dental Office/Practice/Facility solicits input from employees on safety devices as follows: Employees are actively encouraged to solicit and review current information on new safety devices as it becomes available. Employees meet: quarterly annually as per office calendar to review sharps (needles etc..) and/or sharp instruments with engineered sharps injury protection that have become available during this time period. If appropriate, recommendations will be made to the employer as to the selection of the alternative devices. Please note: Employees are required to meet at least annually. Small offices may discuss and make recommendations on a more informal basis. A dental office should only consider needlesafe devices that have been first tested and approved by both the Food and Drug Administration (FDA) and the American Dental Association (ADA). FDA and ADA approved devices can then be further evaluated by dentists and staff for potential use within individual offices. (Please see page a8 for a list of suggested criteria for dental offices to use when evaluating a needlesafe device.) This exposure control plan is reviewed annually to reflect new instruments and/or equipment now in use in this dental office/practice/facility as the result of the Needlestick Safety and Prevention Act. Solicitation of input from employees is documented in this exposure control plan by completing the Needlestick Safety and Prevention Act Form (see page 10-11). OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 9

14 NEEDLESTICK SAFETY AND PREVENTION ACT FORM Listed below are the employees involved in selecting, disseminating and collecting data relative to the following new safety devices. EMPLOYEE NAME Jane Doe John Smith POSITION/TITLE Dental Hygienist Dental Assistant FORM Describe the process whereby input is requested: Annual meetings in which employees discuss alternative safety devices with the employer. Meeting date(s): 4/2006 4/2007 4/2008 Minutes of Meeting(s) x Attached to this form Other: (Please Specify) Copies of documents used to request employee participation x Attached to this form Other: (Please Specify) Records of responses received from employees to the employer(s) (Such as reports evaluating effectiveness of a safer device) x Attached to this form Other: (Please Specify) 2s SAMPLE OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 10

15 NEEDLESTICK SAFETY AND PREVENTION ACT FORM For use in this dental office/practice/facility Listed below are the employees involved in selecting, disseminating, and collecting data relative to the following new safety devices. EMPLOYEE NAME POSITION/TITLE FORM Describe the process whereby input is requested: 2 Meeting date(s): Minutes of Meeting(s) Attached to this form Other: (Please Specify) Copies of documents used to request employee participation Attached to this form Other: (Please Specify) Records of responses received from employees to the employer(s) (Such as reports evaluating effectiveness of a safer device) Attached to this form Other: (Please Specify) FOR USE IN OFFICE FOR USE IN OFFICE Reminder: Don t forget to attach the actual documents that have been indicated on the checkboxes. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 11

16 ENGINEERING AND WORK PRACTICE CONTROLS CONTINUED In this Dental Office/Practice/Facility: D. WASHING FACILITIES Washing facilities are available and readily accessible to all employees. Hands are washed thoroughly with warm water and the anti-microbial soap solution provided for this purpose immediately after removal of gloves. Other skin areas are washed immediately or as soon as feasible after being contaminated with blood or other potentially infectious materials. E. DISPOSABLE SHARPS Recapping Needles- Rationale and Procedure: In dentistry, administering incremental doses of anesthetic to the same patient is often necessary and local anesthetic syringes are reusable when used on the same patient during a single dental appointment. It is necessary, therefore, to recap needles between use and to remove needles from the syringe after of each patient s treatment. Handling and disposal of needles without strict compliance with the following protocol can lead to serious exposure to blood and other potentially infectious materials. Employees have been trained to perform these procedures safely and in accordance with OSHA Bloodborne Pathogens Standard. Contaminated needles are uncoupled from syringe and immediately disposed of in the sharps containers provided for this purpose. Sharps containers are located as close as possible to the site of use. Contaminated needles are never bent, sheared or purposely broken. Needle recapping is performed: by the one-handed scoop method OR by using mechanical devices OR Other: (Please specify) OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 12

17 ENGINEERING AND WORK PRACTICE CONTROLS CONTINUED In this Dental Office/Practice/Facility: F. OTHER CONTAMINATED DISPOSABLE SHARPS Contaminated disposable sharps such as scalpel blades, suture needles, broken instruments, broken glass, orthodontic wires and anesthetic carpules (which may cause injury and therefore exposure to blood if broken) are handled as follows: Broken carpules (scalpel blades, suture needles, broken instruments, broken glass, orthodontic wires and anesthetic carpules) are picked up with forceps or brush and pan and placed immediately in the sharps container. Other: (Please specify) G. REUSABLE SHARPS Many reusable dental instruments and appliances used in dentistry are sharp and, if handled improperly, can cause injury and exposure to blood and other potentially infectious materials. To avoid potential injury when handling these instruments and appliances these procedures are followed: During treatment that requires the use of reusable sharps (e.g., explorers, excavators, endonditc instruments), instruments are passed to the assistant/operator in a firm and deliberate manner. Work surfaces are organized to minimize accidental injury with sharps. Sharp instruments are within the full vision of the individual who is reaching for them. After patient treatment and during clean-up, contaminated instruments are always handled with heavy-duty gloves. Instruments are removed from the ultrasonic cleaner by lifting them from the basket. Other: (Please specify) OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 13

18 ENGINEERING AND WORK PRACTICE CONTROLS CONTINUED In this Dental Office/Practice/Facility: H. WORK AREA RESTRICTIONS Eating, drinking, applying makeup or lip balm, smoking or handling contact lenses is prohibited in all areas where there is potential for contamination with blood or other potentially infectious materials. The above activities may not be conducted in the following areas: For example: Patient Treatment Rooms Laboratories Sterilizing Room Other: (Please specify) The activities listed above (e.g., eating, drinking) are allowed in the following areas of this dental office/practice/facility: Food and beverages are not kept in refrigerators, freezers, shelves, cabinets or on counter tops or bench tops where blood or other potentially infectious materials are present. Food and beverages may be safely stored in the following areas in this dental office/practice/facility: OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 14

19 ENGINEERING AND WORK PRACTICE CONTROLS CONTINUED In this Dental Office/Practice/Facility: I. IMPRESSIONS/APPLIANCES/EQUIPMENT ETC. Universal precautions are used at all times whenever handling anything contaminated with blood or other potentially infectious materials. It is not necessary therefore to label impressions and/or appliances, etc. when handling and transporting them within this dental office/practice/facility. All materials (impressions, appliances, etc.) are decontaminated (see below) before entering the office in-house laboratory. All materials (impressions, appliances, etc.) are decontaminated (see below) before packaging for shipping to an outside laboratory. Decontamination method used: 1) Rinse away saliva and debris with running water AND 2) Immerse in OR 2) Spray with (Name of the disinfectant used and immersion time as per package instructions) (Name of the disinfectant used and contact time as per package instructions) Equipment, which has been contaminated with blood or other potentially infectious materials, is decontaminated before servicing or shipping. Contaminated equipment, which cannot be decontaminated before servicing or shipping, will be identified with a biohazard-warning label. (See page 29) OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 15

20 PERSONAL PROTECTIVE EQUIPMENT The personal protective equipment used in this dental office/practice/facility is considered appropriate because it does not permit blood or other potentially infectious materials to pass through or reach employees work or street clothing, skin, eyes, mouth or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment is used. Directions: The spaces below are to be completed with the employer s name. shall ensure that employees use personal protective equipment appropriate to the task being performed. (Unless the employer shows that the employee temporarily and briefly declined to use Personal Protective Equipment when under rare and extraordinary circumstances, it was the employee s professional judgment that in the specific instance its use would have prevented the delivery of health care and public safety services and posed an increased hazard to the safety of the worker or co-worker. When the employee makes this judgment, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future.) shall ensure that appropriate personal protective equipment is issued without cost to employees. shall ensure that employees remove personal protective equipment after it becomes contaminated in such a way as to avoid skin contact with the outside surface. shall ensure employees remove personal protective equipment before leaving the work area. EMPLOYER PAGE ATTENTION Directions: The spaces below are for the employer s or assigned staff person s name. shall ensure that suitable personal protective equipment is available in suitable sizes. shall ensure that personal protective equipment is readily accessible at the work site. shall ensure that hypoallergenic gloves, glove liners, powder-free gloves or other similar alternatives are readily accessible to those employees who are allergic to the gloves normally provided. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 16

21 PERSONAL PROTECTIVE EQUIPMENT CONTINUED In this Dental Office/Practice/Facility: A. GLOVES SINGLE-USE GLOVES are worn at all times where it is reasonably anticipated that employees will have hand contact with blood or other potentially infectious materials, non-intact skin and/or mucous membranes; when performing vascular access procedures and when laundering or touching contaminated items or surfaces. These gloves are replaced as soon as practical when they become contaminated or as soon as their ability to function as a barrier is compromised. These gloves are not washed or decontaminated for reuse. REUSABLE GLOVES (heavy duty, utility gloves) are worn when cleaning and decontaminating patient treatment areas; transporting and cleaning contaminated instruments after patient treatment is completed. REUSABLE GLOVES are used for cleaning and decontaminating lab areas. REUSABLE GLOVES are decontaminated for re-use provided the integrity of the glove is not compromised. Utility gloves are discarded if they are cracked, peeling, torn, punctured or exhibit other signs of deterioration or when their ability to function as a barrier is compromised ALL GLOVES are provided for use in the appropriate size for the user. All employees with allergies to the glove material or powder inside the glove are provided with powder-free and/or non-allergenic gloves and/or glove liners. B. EYE AND FACE PROTECTION Masks, in combination with eye protection devices such as goggles or glasses with solid side shields or chin-length face shields, are required to be worn whenever splashes, spray, splatter or droplets of blood or other potentially infectious materials may be anticipated. C. PERSONAL PROTECTIVE CLOTHING Protective clothing is worn whenever it is reasonably anticipated employees work clothes, street clothes, undergarments or skin may become contaminated with blood or other potentially infectious materials. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 17

22 PERSONAL PROTECTIVE EQUIPMENT CONTINUED In this Dental Office/Practice/Facility: D. RESUSCITATION MASKS OR DEVICES Mouthpieces, resuscitation bags, pocket masks and/or ventilation bags are readily available for emergency situation and/or CPR training. Location of resuscitation device(s): E. OTHER PROTECTIVE CLOTHING/DEVICES Additional protective wear is worn, as appropriate, for the task being performed. Situations which would require such protection (e.g., gloves, masks) are as follows: F. DISPOSAL, STORAGE, CLEANING AND LAUNDERING Personal protective equipment (e.g., gloves, masks) is disposed of as follows: (List appropriate containers for disposal) Reusable personal protective equipment (e.g., goggles, face shields, resuscitation masks or devices) are cleaned as follows: Gowns/lab coats are stored before laundering in appropriately labeled/color-coded containers and laundered by: Gowns/lab coats are laundered at NO COST to employees. All repairs and replacements of personal protective equipment are made at NO COST to employees (e.g., gloves, masks). OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 18

23 HOUSEKEEPING In this Dental Office/Practice/Facility: A. GENERAL HOUSEKEEPING This dental office/practice facility is cleaned and decontaminated according to a regular schedule: Daily Other: (Please specify) B. CLINICAL AREA DECONTAMINATION All surfaces/equipment contaminated with blood or other potentially infectious materials are decontaminated by utilizing the following EPA registered, tuberculocidal disinfectant(s): (Name of disinfectant(s)) A spray/wipe/spray method of decontamination is used. Surfaces are left wet for minutes (as prescribed by the manufacturer). All contaminated work surfaces are decontaminated after completion of patient treatment procedures and immediately or as soon as feasible after any spill of blood or other potentially infectious materials, and also at the end of the work shift if the surface has become contaminated since the last cleaning. Protective covers are used to shield equipment or surfaces which, because of location or design, are difficult to clean and disinfect adequately. All bins, pails, cans and similar receptacles are inspected and decontaminated on a regularly scheduled basis. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 19

24 HOUSEKEEPING CONTINUED C. IN-HOUSE LAUNDRY PROCEDURES Universal precautions are utilized in the handling of all contaminated laundry. No labeling or color-coding of individual pieces of contaminated laundry is required in the dental office (although appropriate labeling of the bags and/or containers that the contaminated laundry is stored in is recommended). Employees are educated to recognize the hazards associated with the handling of contaminated laundry. Employees handling laundry contaminated with blood or other potentially infectious materials occurs as little as possible. Laundry not labeled is placed in appropriately labeled bags and/or containers. Circle one: Biohazard labeled OR Color-coded red bag When laundry is wet, it is stored in a leak proof container. Please note: If this facility ships contaminated laundry off-site to another facility the scope of work contract with the launderer will be required to utilize the equivalent of universal precautions. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 20

25 REGULATED WASTE DEFINITION OF REGULATED WASTE: Liquid or semi-liquid blood or other potentially infectious materials Contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state, if compressed Items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling Contaminated sharps Pathological and microbiological wastes containing blood or other potentially infectious materials In this Dental Office/Practice/Facility: Regulated waste is placed in containers which are closeable, constructed to contain all contents and prevent leakage. Regulated waste is placed in appropriately identified containers: Circle one: Biohazard Labels OR Red Containers Regulated waste containers are closed prior to removal to prevent spillage or protrusion of contents during handling. REGULATED WASTE SERVICE: Name Address Phone Number OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 21

26 HEPATITIS B VACCINATION AND ANTIBODY TESTING Directions: The spaces below are to be completed by the employer. makes available the Hepatitis B vaccine series to all covered employees (identified in this Exposure Control Plan) who are at risk of occupational exposure, at no cost to them after training and within 10 days of initial employment. Please note: Vaccination is encouraged unless (1) documentation exists that the employee has previously received the vaccine series, (2) antibody testing reveals that the employee has previously received the series or (3) medical evaluation shows that vaccination is contraindicated. ensures that one or two months following the Hepatitis B vaccination series all employees who are at risk of occupational exposure will be tested for HBV surface antibody. ensures that vaccination is performed by or under the supervision of a licensed physician, or by or under the supervision of another licensed health care professional. Name/address of licensed physician or licensed healthcare professional has determined that all laboratory testing is conducted by an accredited laboratory. Evidence of such accreditation is on file. Please note: It is the employer s responsibility to assure that all laboratory tests be conducted by an accredited laboratory. Employer documentation (e.g., certification to verify this accreditation, such as CDC or College of American Pathologists or equivalent state agency, which participates in a recognized quality assurance program) is required. ensures that employees who decline the Hepatitis B vaccination have signed the OSHA required waiver indicating their refusal found on page 24 of this Exposure Control Plan. ensures that if an employee initially declines the Hepatitis B vaccination, but at a later date, while still covered under the Bloodborne Pathogens Standard, decides to accept the vaccination, the vaccination shall then be made available at no cost to the employee. EMPLOYER PAGE ATTENTION OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 22

27 HEPATITIS B VACCINATION AND ANTIBODY TESTING CONTINUED will file a statement (from the health care professional responsible for vaccination) which states whether the employee can or cannot be vaccinated for whatever reason and that, where appropriate, the vaccine has been administered. This is called the Healthcare Professional s Written Opinion. will assure that the vaccination program is instituted and performed. Directions: The space below is to be filled in with the name of the person conducting the training. provides training to employees on Hepatitis B vaccinations, addressing safety, benefits, efficacy, methods of administration and availability. For more information on training requirements see pages in this Exposure Control Plan. EMPLOYER PAGE ATTENTION OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 23

28 HEPATITIS B VACCINATION DECLINATION FORM MANDATORY For use in this dental office/practice/facility I understand that, due to my occupational exposure to blood or other potentially infectious materials, I may be at risk of acquiring Hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with Hepatitis B vaccine, at no charge to myself. However, I decline Hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring Hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with Hepatitis B vaccine, I can receive the vaccination series at no charge to me. Employee signature Date OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 24

29 POST-EXPOSURE EVALUATION AND FOLLOW-UP For use in this dental office/practice/facility In this Dental Office/Practice/Facility: When an employee receives an occupational exposure to blood or other potentially infectious material, first aid (e.g., clean the wound, flush the eyes or other mucous membrane) is administered as soon as feasible. All exposure incidents that occur are reported, investigated and documented. When the employee incurs an exposure, it is reported to: (Name of assigned staff person or employer) (Name of assigned staff person or employer) Following a report of an exposure incident, the exposed employee will immediately, or as soon as possible (within 24 hours) be referred to the appropriate contracted health care provider for follow up. (Name, phone number, address of contracted health care provider) THE ABOVE STATED CONTRACTED HEALTH CARE PROVIDER will ensure that the exposed employee will immediately, or as soon as possible, receive a confidential medical evaluation and follow up including all of the following elements: Documentation of the routes of exposure and how the exposure incident occurred Identification and documentation of the source individual, unless it can be established that identification is infeasible or prohibited by state or local law The source individual s blood shall be tested as soon as feasible and after consent is obtained in order to determine Hepatitis B virus (HBV), Hepatitis C virus (HCV) and Human Immunodeficiency Virus (HIV) infectivity If the source individual is already known to be HBV, HCV and/or HIV positive, further testing need not be performed The health care provider must assure that the exposed employee is provided with the source individual s test results while complying with all laws protecting confidentiality of the source and exposed individuals OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 25

30 POST-EXPOSURE EVALUATION AND FOLLOW-UP CONTINUED If source patient consent is not obtained: (Name, address of contracted health care provider/facility) shall establish that required consent cannot be obtained. Please note: Involuntary testing is limited by law and the conditions under which this can be performed are prescribed in Chapter of the Wisconsin Statutes. A copy of this regulation can be obtained by visiting the Division of Public Health web site ( or contacting the WDA see appendix for contact information. After obtaining consent, the exposed employee s blood will be drawn and tested for HBV, HCV and HIV serological status. If the employee does not give consent to test for baseline HIV during collection of blood, the baseline blood sample may be preserved for at least 90 days. If the exposed employee elects to have this baseline sample tested during this waiting period, the test should be performed as soon as feasible. Following a report of an exposure incident, the employer will ensure that the health care provider responsible for the employee s post-exposure follow-up is provided with the following documentation: 1) copy of the OSHA Bloodborne Pathogens Standard 29CFR ) A copy of the Occupational Exposure Incident Report (see page 28 of this Exposure Control Plan) which includes the following: A written description of the employee s job duties relevant to the exposure incident Route(s) of exposure Circumstances of the exposure If possible, results of the source individual s blood test All medical records relevant to the appropriate treatment of the employee, including vaccination status Following a report of an exposure incident, the employer will obtain and provide the employee with a copy of the evaluating Healthcare Professional s Written Opinion within 15 days of the completion of the post-exposure evaluation and follow-up. This document includes the following: Whether Hepatitis B vaccine is indicated in this case and if this person has received such vaccination statement that the employee has been informed of the results of the post-exposure evaluation A statement that the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials which required evaluation or treatment; all other findings or diagnoses shall not be included in the written report Please note: Timely reporting and follow-up of an exposure incident is essential so that chemical prophylaxis, if appropriate, can be administered in the most effective manner (within two hours if source patient is HIV carrier, otherwise within 24 hours). OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 26

31 OCCUPATIONAL EXPOSURE INCIDENT REPORT A SIGNIFICANT EXPOSURE OCCURS: 1) Following percutaneous exposure (i.e., penetration of dental health care worker s skin by a needle, a scalpel blade or other sharp object contaminated with a patient s blood or other potentially infectious materials). 2) Following contact between dental health care worker s oral or nasal mucous membrane, cornea or non-intact skin and patient blood, saliva or other potentially infectious materials (i.e., a splash of patient blood, saliva or other potentially infectious materials into the mouth, nose or eye of the dental health care worker or direct contact of patient blood saliva or other potentially infectious material with an abrasion, cut or other opening in the skin of the dental health care worker). EMPLOYEE INFORMATION Exposed employee s name: Jane Doe FORM Phone: Position: (414) Dental Hygienist 3s Date of exposure: Date of HBV Vaccination: Date of Anti HBs test: Date of last tetanus toxoid Vaccination: INCIDENT DESCRIPTION: (What occurred and where did it happen? Describe the exposure and whether this is a percutaneous, mucous membrane or corneal exposure as described above. What body part was affected?) Needle stick, left thumb, while administering injection Source patient antibody status (if known): SOURCE PATIENT INFORMATION Source Patient HBsAg status: Positive x Negative HIV antibody status: Positive x Negative Source Patient HCV antibody status: Positive x Negative I, Jane Doe understand the significance of my exposure, as described above, I have been offered medical evaluation and treatment for the exposure but have decided, for personal reasons, not to have any such treatment. Dr. John Doe (Employer s signature) 00/00/ /00/ /00/ /00/0000 Jane Doe (Employee s signature) SAMPLE This document is CONFIDENTIAL and must be maintained by the employer for the length of employment plus 30 years. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 27

32 OCCUPATIONAL EXPOSURE INCIDENT REPORT For use in this dental office/practice/facility A SIGNIFICANT EXPOSURE OCCURS: 1) Following percutaneous exposure (i.e., penetration of dental health care worker s skin by a needle, a scalpel blade or other sharp object contaminated with a patient s blood or other potentially infectious materials). 2) Following contact between dental health care worker s oral or nasal mucous membrane, cornea or non-intact skin and patient blood, saliva or other potentially infectious materials (i.e., a splash of patient blood, saliva or other potentially infectious materials into the mouth, nose or eye of the dental health care worker or direct contact of patient blood saliva or other potentially infectious material with an abrasion, cut or other opening in the skin of the dental health care worker). EMPLOYEE INFORMATION Exposed employee s name: Phone: Position: FORM 3 Date of exposure: Date of HBV Vaccination: Date of Anti HBs test: FOR USE IN OFFICE Date of last tetanus toxoid Vaccination: INCIDENT DESCRIPTION: (What occurred and where did it happen? Describe the exposure and whether this is a percutaneous, mucous membrane or corneal exposure as described above. What body part was affected?) Source patient antibody status (if known): SOURCE PATIENT INFORMATION Source Patient HBsAg status: Positive Negative HIV antibody status: Positive Negative Source Patient HCV antibody status: Positive Negative I, understand the significance of my exposure, as described above, I have been offered medical evaluation and treatment for the exposure but have decided, for personal reasons, not to have any such treatment. (Employer s signature) (Employee s signature) This document is CONFIDENTIAL and must be maintained by the employer for the length of employment plus 30 years. OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 28

33 COMMUNICATION OF HAZARDS TO EMPLOYEES AND TRAINING In this Dental Office/Practice/Facility: LABELS AND SIGNS (Name of assigned staff person) Will ensure that biohazard labels are affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious materials and other containers used to store, transport or ship blood or other potentially infectious materials (e.g., extracted teeth, biopsy material). The universal biohazard symbol is used and this label must be fluorescent orange or orange red. Please note: Red bags or containers may be substituted for labels. However, regulated waste is handled in accordance with the rules and regulations of the agency (Wisconsin Department of Natural Resources) having jurisdiction over waste disposal regulations. EMPLOYER PAGE ATTENTION OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 29

34 INFORMATION AND TRAINING In this Dental Office/Practice/Facility: (Employer s Name) Will ensure that training is provided at the time of the initial assignment of tasks where occupational exposure may occur and that it is repeated within 12 months of the previous training. The training will be tailored to the education and language level of the employee and offered during the normal work hours. The training provided in this dental office/practice/facility is interactive and covers the following: copy of the OSHA standard and an explanation of its contents A discussion of the epidemiology, symptoms and modes of transmission of blood borne pathogens, including HIV, HBV and HCV An explanation of this office s Bloodborne Pathogens Exposure Control Plan and a how to obtain a copy An explanation of methods to recognize tasks and other activities that may involve exposure to blood and other potentially infectious materials, including what constitutes an exposure incident An explanation of the use and limitations of engineering controls, work practices and personal protective equipment including specific training on engineered sharps used An explanation of the basis of selection of personal protective equipment Information on the types, use, location, removal, handling, decontamination and disposal of personal protective equipment Information on the Hepatitis B vaccination, including information on its efficacy, safety, method of administration, the benefits of being vaccinated and that the vaccine will be offered free of charge Information on the appropriate actions to take and persons to contact in an emergency involving exposure to blood or other potentially infectious materials An explanation of the procedures to follow if an exposure incident occurs, including the methods of reporting the incident and the medical follow up that will be made available Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident Information on timely reporting of an exposure incident so that chemical prophylaxis, if appropriate, can be effectively administered in a timely manner An explanation of the signs, labels, and/or color-coding required by the standard and used in this office/practice/facility EMPLOYER PAGE ATTENTION OSHA EXPOSURE CONTROL PLAN a member benefit from the WDA 30

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