Regulatory Compliance: Infection Control Do's and Don'ts

CDA Practice Support

This article reviews some of the infection control topics about which CDA members have contacted Practice Support.

DO’s

Screen patients for aerosol-transmissible diseases. California dental practices have been required to conduct this screening since Cal/OSHA approved the aerosoltransmissible diseases regulation in 2009. The screening is one of four conditions dental practices must meet to be exempt from the majority of ATD regulation requirements. The other three conditions are: A written procedure for screening patients that is consistent with current CDC guidelines must be included in a practice’s injury and illness prevention plan; employees must be trained in the procedure; and aerosol-generating procedures may not be performed on a patient who is identified by the screening procedure as a possible ATD exposure risk.

Provide timely training. Provide a new employee with bloodborne pathogens exposure control training before or at the time of assignment to tasks that can expose them to blood, saliva or other potentially infectious material. An experienced staff member can provide the required training by using training materials such as the dental practice’s exposure control plan, online training and relevant articles like those on the CDC website or in professional journals. The trainer must address the 14 topics required in the Cal/OSHA regulation.

Offer required vaccination. Offer a new employee the hepatitis B vaccination series if their job potentially exposes them to blood, saliva or other potentially infectious materials (OPIM). Cal/OSHA requires employers to offer the vaccination after providing the required bloodborne pathogens training and within 10 working days of the initial work assignment. The offer need not be made if the employee has previously received the vaccination series, antibody testing reveals the employee is immune or the vaccine is contraindicated for medical reasons. For more information on the requirement, see “Hepatitis B Vaccination: Requirement and Recommendations.”

Have required written protocols. Have written protocols for instrument processing, operatory cleanliness and injury management as required by the dental board in its infection control regulation. Dental plan auditors are known to request the protocols when auditing a practice. Sample protocols are included in CDA’s “Regulatory Compliance Manual.”

Designate an infection control coordinator. This is a leadership role. A key staff member can ensure consistent application of infection control protocols, train staff and maintain necessary and required documentation.

DONT’S

Avoid an employer’s responsibility. Job applicants and new employees may not be required by an employer to undergo a prescreening as a prerequisite for receiving the hepatitis B vaccination series.

Confuse “uniforms” with “personal protective equipment.” The bloodborne pathogens regulation does not include the terms “scrubs” or “uniforms.” It requires the use of “personal protective equipment” (PPE).

The question “who is responsible for laundering scrubs” cannot be answered by looking at the regulation. Scrubs may be worn in the practice because they are comfortable and can provide a uniform look for the staff. However, scrubs cannot be used as PPE because they do not fit the following description provided by Cal/OSHA:

PPE will be considered “appropriate” only if it does not permit blood or other potentially infectious material (OPIM) to pass through employees’ underlying garments or to reach the skin, eyes, mouth or other mucous membranes under normal conditions of use. PPE must retain this capability during the entire course of its use by the employee. This allows the employer to select PPE based on the type of exposure and the quantity of blood or OPIM reasonably anticipated to be encountered during performance of a task or procedure. [1]

A gown that covers the arms to the wrist, the neck and covers an individual’s lap while sitting is appropriate PPE in a dental practice.

Incorrectly believe the dental boardrequired infection control continuing education to be the same as annual bloodborne pathogens training. Both Cal/ OSHA and the dental board have regulations governing infection control in dental settings. Both agencies require training that cover similar subjects, but each has slightly different requirements. The dental board requires licensed professionals to take a two-hour infection control course every license renewal period. The course must be approved by the dental board and must be provided by a dental board-approved continuing education provider. The course content must relate to the dental board’s infection control regulations.

Cal/OSHA requires employers to provide bloodborne pathogens training to occupationally exposed employees upon hire, whenever a change in procedures may lead to increased exposure and at least annually. The training must be offered during work hours, at no cost to the employee, and be provided by a knowledgeable trainer. There is no minimum time requirement for the training, but it must cover:

■ Epidemiology and symptoms of bloodborne diseases.

■ Modes of transmission of bloodborne pathogens.

■ The dental practice’s exposure control plan, the bloodborne pathogens regulation and means to obtain a copy of both.

■ How to recognize tasks that may involve exposure.

■ Use and limitations of engineering controls, work practices and PPE.

■ Type, use, location, handling, decontamination and disposal of PPE.

■ Explanation of basis for selection of PPE.

■ HBV vaccine information: efficacy, safety, method of administration, benefits, offered at no cost to employees.

■ Actions to take and who to contact in an emergency involving infectious materials.

■ Postexposure procedures including reporting, medical follow-up and sharps injury log recording.

■ Employer’s requirements for postexposure evaluation and follow-up.

■ Signs and labels.

REFERENCE

1. California Department of Industrial Relations Cal/OSHA. Frequently asked questions about the bloodborne pathogens standard. Accessed April 22, 2022.

Regulatory Compliance appears monthly and features resources about laws that impact dental practices. Visit cda.org/ practicesupport for more than 600 practice support resources, including practice management, employment practices, dental benefit plans and regulatory compliance.