Volume 1, Issue 2
Bloodborne Pathogens Newsletter Course # 02-5038-12001
AGGIE DENTAL COMPLIANCE (888) 418-6163
February 1, 2012
Bloodborne Pathogens Training # 02-5038-12001 All employed healthcare workers that can be potentially exposed to blood and other potentially infectious material (OPIM) are mandated by OSHA to participate in yearly Bloodborne Pathogens training. Dental practice owners are exempt because they are employers not employees. An employer is ultimately responsible to make sure their staff receives training free of costs and trained during regular office hours. Employees that must receive training, include but not limited to DA, RDA, RDH and employed DDS.
AGGIE Dental Compliance
A Dental Professional has the right to choose from live or correspondence BBP training. Live training is when a registered CE provider conducts the class and correspondence is when you read a newsletter and take a short test. This issue fulfills the Mandatory requirement of BBP Training throughout the country.
AggieDC.com (888) 418-6163 Ask for Rick Aguilar
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2 Free CE BBP Training*
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Spore Testing
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Personal Protective Equipment
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Certificate of completion
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OSHA Inspection guidelines
I hope that you find this course easy to read. The Newsletter will explain the BBP laws set in place to protect you from exposure to blood and OPIM. Today’s Newsletter is free and transferrable. You are encouraged to share the publication with any Dental Professional. Read our Newsletter and then fax test answers to receive your certificate of completion.
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Studying the Exposure Control Plan The Exposure Control Plan (ECP) may be the most important plan in your office for many reasons. First of all 8 of the top 10 dental OSHA citations are related to ECP mistakes. Having a strong and recently updated plan virtually eliminates any chance of getting cited by OSHA. Your plan should have information and input from your dental office co-workers in the areas of Hepatitis B (HBV) protocols, the risks of each employees job description, input for engineered sharps, and safety equipment. Did you know that EVERYONE in the office should have a say in engineered safety sharps review in the Exposure Control Plan? Why?? Because dental offices are getting cited for not asking front office employees. I don't know why it’s happening I just know that in recent years this citation has reached the Top 10
Prevention Action: Review your Exposure Control Plan today if you have not done so in the last year FREE consultation: Ask for Rick Aguilar (888) 418-6163 AggieDC.com
Personal Protective Equipment (PPE) All Dental Professionals (DP) shall wear surgical facemasks in combination with either chin length plastic face shields or protective eyewear whenever there is potential for aerosol spray, splashing or spattering of the following: droplet nuclei, blood, chemical or germicidal agents or OPIM. Chemical-resistant utility gloves and appropriate, task specific PPE shall be worn when handling hazardous chemicals. After each patient treatment, masks shall be changed and disposed. After each patient treatment, face shields and protective eyewear
shall be cleaned, disinfected, or disposed. Protective attire shall be worn for disinfection, sterilization, and housekeeping procedures involving the use of germicides or handling contaminated items. Wear reusable or disposable protective attire whenever there is a potential for aerosol spray, splashing or spattering of blood, OPIM, or chemicals and germicidal agents. Protective attire must be changed daily or between patients if they should become moist or visibly soiled. All PPE used during patient care shall be
What about scrubs?
removed when leaving laboratories or areas of patient care activities. Reusable gowns shall be laundered in accordance with Cal/OSHA BBP Standards. Dental office owners pay for PPE.
Keep lab coats out of the lobby area and you will be fine. NO need to take it off in the patient area
In a dental office setting scrubs are not PPE. It just so happens that when a person wears “street” clothes underneath scrubs the scrubs then technically can be considered PPE. This statement is my opinion based on the fact that no dental practice owner has been ever cited by OSHA or a dental board for not proving free scrubs to their staff.
VOLUME 1, ISSUE 2
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Post Exposure Evaluation
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What is to be done if someone does get hurt on the job. The Post Exposure Evaluation is a guideline of the steps to take if a dental office employee is exposed to blood. Please refer to your Exposure Control Plan for more details and to document the incident.
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Administer First Aid. Clean the injured area ( in dentistry likely the hand) and put a band aid on the puncture area.
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Send the injured employee to go see a medical doctor within 24 hrs
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Document how the exposure happened within 30 days
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If possible, contact the source patient and begin blood work ( Practice owner pays all costs)
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The injured employee is offered counseling by medical doctor and receives evaluation for any disease related to the work injury
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Sharps log is updated to reflect injury
Epidemiology of Bloodborne Pathogen diseases HIV
Hepatitis B (HBV)
Hepatitis C (HCV)
HIV is the virus that causes AIDS. HIV transmission is extremely low in dental settings. Prospective studies worldwide indicate the average risk of HIV infection after a single needle puncture exposure to HIV blood is 0.3%. The rate is even lower for transmission via saliva or other potentially infection material.
HBV is the health care providers most transmitted Bloodborne Pathogen. Like HIV it is transmitted by blood and OPIM. HBV has been proven potentially infectious in dried blood for as long as a week!
The transmission of Hepatitis C Virus can occur via improper handling and cleaning of dental instruments. The Centers for Disease Control and Prevention assert that hepatitis C infection is the most common chronic blood-borne infection in the United States. These investigators determined the seroprevalence of HCV infection among participants in the National Health and Nutrition Examination Survey, conducted in the United States from 1988 to 1994 to be 1.8% . The rates within the dental community is much lower. The incubation period for HVC is about 8 weeks. Symptoms include fever, jaundice, and dark urine.
HIV gradually depletes the number of cells that are essential for immune function. Infection of HIV is confirmed with a blood test that searches for HIV antibodies. A majority of infected people show detectable antibodies 6-12 months after transmission. Symptoms include fever, muscle pain, tiredness, weightless, and nausea.
This is why it is important to use a disinfectant that kills HBV and to assume everyone is infected. HBV attacks the liver. One third of infected people show any symptoms, one third only develop mild symptoms, and the last third show no symptoms whatsoever. It’s not my intention to scare you about some of the information discussing HBV. The fact is an HBV transmission in dentistry has not been reported since Def Leppard released “Pour some sugar on me” back in 1987. A strong HBV vaccination program plays a big part in this statistic.
VOLUME 1, ISSUE 2
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OSHA 101: Inspections
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Who is OSHA? OSHA stands for Occupational Safety and Health Administration. OSHA is part of the Department of Industrial Relations. It was created to make sure that employees are not being forced to work under unsafe working conditions. For example, OSHA is responsible for overseeing employees who have a potential exposure to blood to work under conditions that limit chances to having an accident. An XRay Tech needs to wear gloves when placing bitewings in a patients mouth and an RDH needs to wear goggles and a face shield when cleaning teeth.
How is a dental office chosen to be inspected? •
Priority #1:- Is given to places of employment that have imminent danger situations. An imminent danger is any condition where there is reasonable certainty that a danger exists that can expect to cause death or serious physical harm immediately. Because dental offices are considered low hazard, I argue that your dental office will NEVER be at the top of the list.
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Priority #2:- Goes to the investigation of fatalities and accidents requiring the hospitalization of 3 or more employees. OSHA will inspect to determine the cause of the accidents and whether existing OSHA standards were violated. Sending an employee to the hospital or Dr’s office after a needle stick will not trigger an inspection.
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Priority #3:- Goes to employee and patient complaints for unsafe working conditions. OSHA will grant anonymity to the person making the complaint. A majority of dental office investigations are because an employee is exercising their safety rights or from employee with as grievance against their employer.
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Priority #4:-The last to be inspected are programmed inspections. OSHA selects industries for inspection on the basis of factors such as the injury rates, previous citation history, and employee exposure to toxic substances. In general, programmed inspections are for high hazard industries like huge processing plants. Dental offices are considered low hazard.
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VOLUME 1, ISSUE 2
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What is OSHA looking for during an inspection? Frankly, OSHA can cite your office for any of countless regulations. However, most citations are for failing in one or more of the following areas. •
Bloodborne Pathogen Training and Infection Control. Dental professionals are at risk for exposure to blood and other potentially infectious material (OPIM). A dental practice owner is obligated to give free annual BBP training during normal business hours.
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Exposure Control Plan. One of the most expensive fines is for not having an up to date Exposure Control Plan that has been reviewed yearly. Maximum fine is $2,500.
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Hazard Communication Plan. An up to date plan that has been reviewed in the last 365 days will keep an inspector from fining a dental office.
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Proper Training. Each employee will be properly trained to perform each duty. It is not enough to assume that a person who has graduated from a dental program that the employee can go straight to work. The employee must be advised of your dental offices policies on the handling of sharps, hazardous materials, etc. Most Expensive OSHA fines at a dental office
1) Exposure Control Plan does not reflect changes in technology that reduces exposure to bloodborne pathogens $2,500. 2) Exposure Control Plan does not document the annual consideration of new engineered sharps $2,045. 3) Improperly labeled sharps disposal container $1,500. Most frequent violations for dental offices 1) Employer does not have an updated Exposure Control Plan $854. 2) Employee OSHA training not given at no cost and conducted during normal working hours. $447. 3) Employer does not have documentation of employee declining HBV vaccination series. $70
Find the Top 10 OSHA fines at AggieDC.com
VOLUME 1, ISSUE 2
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The door opens and it’s OSHA.. Ask for credentials. If you question the proof, you may call OSHA at (800) 321-OSHA. • Ask the inspector to have a seat. • Inform the dental practice owner and assigned representative that the inspector is on the grounds.
Opening Conference
• Can you refuse an inspection? Yes. But the inspector will come back with a court order. In the opening conference, the OSHA inspector will explain why they are there and what the scope of the investigation will be. It is at this time the inspector will ask for documentation such as the Exposure Control Plan, MSDS, HBV vaccination status, etc.
The Walkthrough After the opening conference, the inspector and office representative will walk around the dental practice. The inspector observes safety and health conditions and practices, consults with employees privately, examines records, surveys existing engineering controls, and sharps containers. Every employee is protected from discrimination by their employer for speaking up and exercising their rights to safety. In general this step is the longest and will last about 30-60 minutes.
Closing Conference At the conclusion of the inspection, the inspector will hold a conference to discuss his/her findings. The inspector will point out any unsafe or unhealthful working conditions observed. The inspector will also discuss possible corrective actions. Many times, if the corrective action is simple, the inspectors will allow the dental office to correct the violation on the spot. The dental office will have 30 days to correct the other violations. The inspector will advise the employer how to prove that the corrective measures have been taken. Very likely measure will be confirmed by phone, written documentation, or follow up inspection.
VOLUME 1, ISSUE 2
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AGGIE DENTAL COMPLIANCE (888) 418-6163
Are you ready for an OSHA Inspection? Assign a representative to assist the OSHA inspector • Have a copy of Injury Illness Prevention Plan • Have a copy of Exposure Control Plan • Have a copy of Fire and Emergency Plan • Have a copy of Hazard Communication Plan • MSDS binder • Documented proof of BBP Training • Sharps Injury log • Documentation of engineered sharps • HBV vaccination status •
*The plans need to be read, reviewed, and discussed every year. Document by signing and dating each plan.
How to lower fines? OSHA Officers have full discretion when setting a fine. The max that you can be fined may be set in stone but rarely is anyone ever charged the full amount. A good faith towards following OSHA standards effort goes a long way. Take a look at the #1 most frequent violation. An office without an updated Exposure Control Plan is charged on average $854 but according to the highest OSHA violations an un updated Exposure Control Plan can get you fined as high as $2,500. Other factors OSHA will consider are: Good safety record. Violation involves only a few employees. A company can show its honest intensions with
•Written Guarantee to pass OSHA Inspections •2 CE Bloodborne Pathogens Training •2 CE Infection Control •2 CE California Dental Practice Act (CDPA) •Review & Update Exposure Control Plan Did you know 8 of the top 10 OSHA fines are for a poor Exposure Plan? Start up company wants to get to know you. Get Mandatory OSHA Training for FREE. Complimentary first year includes BBP, Infection Control, and CDPA AGGIE Dental Compliance Tel: (888) 418-6163
VOLUME 1, ISSUE 2
Page 7
AggieDC.com AGGIE DENTAL COMPLIANCE (888) 418-6163
Test your knowledge. Answer questions True or False 1.
An RDA is responsible for paying their own BBP Training and complete it on their own time.(pg1)
True / False
2.
An updated Exposure Control Plan eliminates all chances of getting fined.(pg2)
True
3.
Dental practice owners are responsible for buying scrubs for all employees(pg2)
True / False
4.
Recent studies show a high transmission rate of HIV among dentistry.(pg3)
True / False
5.
Last reported case of Hepatitis C in dentistry was in 1987.(pg3)
True / False
6.
OSHA stands for Occupational Safety and Health Administrtation.(pg4)
True / False
7.
A needle stick can trigger a OSHA inspection.(pg4)
True / False
8.
An Exposure Control Plan that has not been reviewed in more than a year can be one of the
9.
/ False
most expensive OSHA fines.(pg5)
True / False
If you question an inspectors credentials, you can call (800) 321– OSHA(pg6)
True / False
10. Inspectors have discretion when they are calculating an OSHA fine.(pg7)
True / False
This test can be taken as a group or be taken individually. Answer 2) F
3)F
4) F
5) T
6) T
7) F
8) T
9) T
10) T
At this time only CA Dental Professionals may get 2 CE from CA Dental Board
1) F
Bloodborne Pathogens Training is approved throughout the country (USA)
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AGGIE Dental Compliance Mandatory Bloodborne Pathogens Training Course # 02-5038-12001 2 Continuing Education Units (CA) Fax: (888) 868-8951
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