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FAQ's Training & Personnel

Frequently Asked Questions (FAQs) on Dental Infection Control


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Frequently Asked Questions for Training & Personnel

Q Does OSAP have a reference or rationale that could be used to explain to an affirmative action officer about the "absence of type IV latex allergy" in the dental world?

Q Is it okay to wear jewelry?

Q What safety precautions are recommended for pregnant healthcare workers?

Q Could a videotape count as training and meet OSHA regulations?

Q There seem to be more dental personnel complaining about dry throats, sniffling, and headaches. Is this a result of the phenolics being sprayed after each patient?

Q Are there any states or institutions that require notification to patients if the healthcare worker is positive for viral hepatitis, HIV, or other infectious diseases?

Q What do you do regarding an employee who is trying to get pregnant but insists on running the x-ray machine?

Q I need to comply with a relicensing requirement for 6 hours of infection control continuing education. Does OSAP have suggestions for where I might obtain the necessary units?

Q What does OSHA require in annual training for bloodborne pathogens?

Q Does OSAP have information on distance learning programs in infection control and occupational safety that are available for dental workers?

Q Are there any recommendations or requirements on how many staff members must be CPR certified in the dental office?

Q Our dental office used the OSAP Interact Training System. When an employee fails to successfully complete the testing do you recommend review and retesting individually or as a team?

Q Where can I find information on upcoming seminars on dental infection control?

Q Can I become a certified OSAP infection control instructor by completing the OSAP Interact Training System program?

Q Which states allow employees to decline their hepatitis B vaccine?

Q How long does an office need to keep records on hazardous waste pick up, laundry for gowns and all other records that OSHA requires?

Q I would like to know how to certify our OSHA training so that it may count toward the new requirements for Continuing Education credits for Dental Hygienists. We have developed a great program, review it upon hire and annually with staff at risk. Do you have any guidance for me?

Q What precautions should I take to be safe in a dental setting when pregnant?

 

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Q Does OSAP have a reference or rationale that could be used to explain to an affirmative action officer about the "absence of type IV latex allergy" in the dental world?

A The National Institute for Occupational Safety and Health (NIOSH) has an extensive list of recent publications regarding occupational latex allergy (1). This should provide you with a reliable source of information for a variety of occupational latex allergy issues.

References:
(1) NIOSH. Occupational Latex Allergies. Available at http://www.cdc.gov/niosh/topics/latex.

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Q Is it okay to wear jewelry?

A Although no regulation specifically prohibits the wearing of jewelry by healthcare workers, there is some concern regarding jewelry worn on the hands by healthcare workers involved in direct patient care.(1) Studies have shown that total bacterial counts are higher when rings are worn, although one study suggests that rings do not interfere with removal of bacteria by handwashing.(2) Nonetheless, rings can make donning gloves more difficult and increase the risk of glove tearing.

References:
(1) Larson, E, APIC. 1994 APIC Guidelines Committee. Guideline for Hand Washing and Hand Antisepsis in Health-Care Settings. Am J Infec Control. 1995;23:251-269.
(2) Jacobson G, Thiele JE, McCune, et al. Handwashing: Ring-wearing and number of microorganisms. Nurs Res 1985;34:186-8

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Q What safety precautions are recommended for pregnant healthcare workers?

A Pregnant workers generally are not considered to be at an increased risk for acquiring infections occupationally. Adherence to appropriate infection control precautions, including standard precautions is indicated. Female workers of childbearing age should ensure that they have received all recommended immunizations and consult with their personal physician regarding which immunizations may require booster doses. The "Guidelines for Infection Control in Health Care Personnel, 1998”(1) provide specific information for precautions for pregnant healthcare workers (See table 6 within the document).

References:
(1) Bolyard EA, Tablan OC, Williams WW, et al. Guidelines for Infection Control in Health Care Personnel, 1998.” AJIC 1998 Jun;25(3):291-354. Available at http://www.cdc.gov/ncidod/dhqp/gl_hcpersonnel.html

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Q Could a videotape count as training and meet OSHA regulations?

A Although videotape can be used for a portion of employee training, no tape can completely and accurately cover all of the specific aspects and differences encountered in each workplace. OSHA requires that a person be available to address practice specifics and answer employee questions and that "The person conducting the training shall be knowledgeable in the subject matter…”(1). According to the OSHA regulation, there must be an opportunity for interactive questions and answers with the trainer. As such, videotapes may be used as a supplement to (and not a replacement for) physical, hands-on, Q&A training.

References:
(1) OSHA. 29CFR 1910.1030. Bloodborne Pathogens Standard, Final Rule. Available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

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Q There seem to be more dental personnel complaining about dry throats, sniffling, and headaches. Is this a result of the phenolics being sprayed after each patient?

A Mild upper-respiratory complaints are non-specific and difficult to apply to specific causes. Scientifically controlled studies related to exposure to any agents are needed before causative statements can be made. Such studies are difficult to conduct and interpret. If spraying chemicals into the environment is causing concern in your office, disinfectants may be applied to surfaces via saturated pads. Dispensers that produce a stream or droplets rather than a spray can also reduce staff exposure to the chemical agent. Using barriers instead of chemical germicides on surfaces between patients also should be considered.

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Q Are there any states or institutions that require notification to patients if the healthcare worker is positive for viral hepatitis, HIV, or other infectious diseases?

A In 1991, the Centers for Disease Control and Prevention (CDC) recommendations on this issue were published.(1) Subsequently, Congress mandated that each state implement the CDC guidelines or equivalent as a condition for continued federal public health funding to that state. Although all states have complied with this mandate, there is a fair degree of state-to-state variation regarding specific provisions. Local or state public health officials should be contacted to determine the regulations or recommendations applicable in a given area. A Hospital Infection Control practices Advisory Committee (HICPAC) document titled "Guideline for infection control in health care personnel, 1998" can provide more information.(2)

References:
(1) CDC. Recommendations for Preventing Transmission of Human Immunodeficiency Virus and Hepatitis B Virus to Patients During Exposure-Prone Invasive Procedures. MMWR Mordbi Mortal Weekly Rep 1991;40(RR-8). Available at http://www.cdc.gov/mmwr/preview/mmwrhtml/00014845.htm
(2) Bolyard EA, Tablan OC, Williams WW, Pearson ML,a Shapiro CN, Deitchman SD,c and The Hospital Infection Control Practices Advisory Committee. Guideline for infection control in health care personnel, 1998. Available at http://www.cdc.gov/ncidod/dhqp/gl_hcpersonnel.html

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Q What do you do regarding an employee who is trying to get pregnant but insists on running the x-ray machine?

A All workers must follow precautions to prevent occupational exposure to radiation emitted from dental x-ray machines. These precautions include ensuring the machines are properly collimated, the worker is never present in the room during exposure of the film, the worker is not in the path of the active beam, the worker is at least 6 feet from the active beam, the proper kVp and MA are utilized, and the highest speed film is used to further reduce the amount of radiation needed to expose the film. Additionally, monitoring exposure through the use of radiation monitoring badges may be considered. No specific restrictions are recommended for pregnant dental workers and each individual should consult their physician for recommended work restrictions.

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Q I need to comply with a relicensing requirement for 6 hours of infection control continuing education. Does OSAP have suggestions for where I might obtain the necessary units?

A There are several infection control course options for continuing education credit.

1. OSAP offers a comprehensive in-office infection control and safety training system called OSAP - Interact. Completion of the videotape and workbook program can earn 10 hours of CE credit.

2. For off-site coursework, the For off-site coursework, the OSAP-Federal Dental Services Intermediate Level Course on Dental Infection Control and Safety is held annually. Attendees can earn more than 30 hours of CE credit.

is held annually in June. The 3-1/2-day event offers at least 18 hours of CE credit.

4.OSAP's calendar of events lists courses led by OSAP members around the country and around the world. Look for a course near you.

5. Each issue of OSAP's Infection Control In Practice newsletter includes a continuing-education test good for 1 hour of AGD credit. OSAP Members receive back issues upon sign-up and pay a discounted processing fee of only $5 per test ($15 for each test for non-members). The newsletter is published 8 times each year.3. The The OSAP Symposium

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Q What does OSHA require in annual training for bloodborne pathogens?

A The Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard requires that all employees with occupational exposure receive training at the time of initial assignment and at least annually thereafter. Employees must also receive additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure.

The elements of the training program must include, at a minimum:
An accessible copy of the regulatory text of the current standard and an explanation of its contents;
A general explanation of the epidemiology and symptoms of bloodborne diseases;
An explanation of the modes of transmission of bloodborne pathogens;
An explanation of the employer's exposure control plan and the means by which the employee can obtain a copy of the written plan;
An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;
An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment;
Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment;
An explanation of the basis for selection of personal protective equipment;
Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;
Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;
An explanation of the procedure to follow if an exposure incident occurs, including the method 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;
An explanation of the signs and labels and/or color coding required by paragraph (g)(1); and
An opportunity for interactive questions and answers with the person conducting the training session.
The standard also requires that the person conducting the training be knowledgeable in the subject matter, and how the information relates to that workplace. The trainer also must provide an opportunity for questions and answers.

In addition to these OSHA requirements, OSAP recommends contacting your state's Board of Dental Examiners(2) to determine if it has any additional requirements for relicensure.

References:
1) OSHA. 29CFR 1910.1030. Bloodborne Pathogens, Final Rule. Available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051
2) The Dental Student Dental Students: The Dental Students Network. State and Regional Dental Practice Boards. Available at http://forums.studentdoctor.net/forumdisplay.php?f=55

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Q Does OSAP have information on distance learning programs in infection control and occupational safety that are available for dental workers?

A A number of distance-learning programs are currently available to dental workers. To name a few:


OSAP's modular workbook and videotape program available called the OSAP Interact Employee Infection Control and Safety Training System
The Phoenix College Center for Health Professionals
DENT 180 Infection Control for Dental Professionals
Baylor College of Dentistry Office of Continuing Education
University of California (UCLA)
University of Texas Health Science Center at San Antonio
For more information on distance learning, check out OSAP's April 2002 newsletter titled "Distance Learning Dental Infection Control and Safety.”

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Q Are there any recommendations or requirements on how many staff members must be CPR certified in the dental office?

A Specific requirements for cardiopulmonary resuscitation (CPR) certification can vary from state to state. Contact your State Board of Dental Examiners for CPR requirements in your state(1).

References:
1) The Dental Student Dental Students: The Dental Students Network. State and Regional Dental Practice Boards. Available at http://forums.studentdoctor.net/forumdisplay.php?f=55

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Q Our dental office used the OSAP Interact Training System. When an employee fails to successfully complete the testing do you recommend review and retesting individually or as a team?

A If a number of employees give incorrect answers to the same question(s), a group post-test review session may be necessary.

If an employee gives incorrect answers to a number of questions, or no other employee gives incorrect answers to the question(s), it may be better to review the test with that employee privately. The employee can explain his/her answers, receive correct information in private, and avoid any possible embarrassment. It should be noted that some individuals simply are poor test takers and may do much better when they can explain their answers in a verbal format.

After providing employee(s) with the necessary review to understand policies, procedures, and rationale, consider re-testing at a future date to ensure understanding of the material.

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Q Where can I find information on upcoming seminars on dental infection control?

A The OSAP website maintains a Dental Infection Control Event Calendar on this website.

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Q Can I become a certified OSAP infection control instructor by completing the OSAP Interact Training System program?

A The OSAP Interact Employee Infection Control and Training System is not a certification program, but an interactive infection control education and training course for employees/personnel in dental healthcare settings. It is to be used in conjunction with site-specific policies and procedures within the each practice setting.

By successfully completing the OSAP Interact course and its corresponding tests, you can earn a certificate of completion and continuing education credit. OSAP awards credit through the Academy of General Dentistry and the Dental Assisting National Board;* OSAP also is an ADA CERP Recognized Provider.

*OSAP is an AGD Approved National Sponsor, FAGD/MAGD credit, 10/23/93 to 12/31/05.

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Q Which states allow employees to decline their hepatitis B vaccine?

A Under the federal Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard 1910.1030, employers must explain the risks of exposure, state the benefits of the hepatitis B vaccine, and offer the vaccine, at no charge, to all employees at risk of exposure to blood or potentially infectious materials. Any employee, in any state, may choose to decline the vaccine.

Employees must understand the risks of disease transmission and the risks and benefits of receiving the vaccination before the employer offers the vaccine. Once they understand these risks and that the vaccine is available to them at the employer's expense, they reserve the right to decline. If they later change their mind, the employer is still obligated to provide the vaccine at not cost to any employee in a job category that involves exposure.

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Q How long does an office need to keep records on hazardous waste pick up, laundry for gowns and all other records that OSHA requires?

A OSAP is not in a position to offer legal advice. Because recordkeeping logs can be a legal issue and play a role in risk management, you should also consult with the dental practice's attorney and/or attorney knowledgeable in medical law. They can provide legal advice on maintaining such records, especially those concerning issues not covered under OSHA standards, other Federal regulations, or specific state laws.

OSAP can provide you with the following general information:

The Bloodborne Pathogens Standard 29 CFR 1910.1030 does state the following:

Medical Records: 1910.1030(h)(1)(iv):

The employer shall maintain the records required by paragraph (h) for at least the duration of employment plus 30 years in accordance with 29 CFR 1910.1020. (1)

Training Records: 1910.1030(h)(2)(ii):

Training records shall be maintained for 3 years from the date on which the training occurred. (1)

OSAP is not currently aware of any federal requirements for maintaining laundry records/logs for gowns. OSHA's Bloodborne Pathogens Standard 29 CFR 1910.1030 does not list this under recordkeeping requirements.

With regard to hazardous waste logs, should the office contract with a waste hauler, the office should be provided with a receipt of shipment (at time of pick-up) and manifest (several weeks later). Once the waste leaves the office the Environmental Protection Agency (EPA) regulations apply. All hazardous waste logs should be maintained for the length of time stipulated by your State and local Environmental Protection Agency.

You may also be interested in resources for waste management that may be viewed at:

http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=72

http://www.deq.state.va.us/p2/mercury/documents/manual.pdf

The sterilization monitoring log record book should be used to record the results of biological monitoring, as well as, mechanical, and chemical process integrators. Sterilization monitoring log record books may be purchased (e.g. through the monitor's distributor/manufacturer, dental sales representative, etc.) or can be developed by the practice. Most dental practices choose to purchase a monitor record log book because they are simple to use and maintain.

Requirements, regulations, and recommendations do vary among states, therefore, records must be maintained long enough to comply with regulations in your state or locality. Sterilization monitoring requirements, including recordkeeping, can be regulated by the State Board of Dental Examiners/Licensing Board, through the State Health Department/Agency and/or through legislative law.

To determine if you are in a state with required recordkeeping regulations and requirements contact your State Board of Dental Examiners/State licensing agency, as well as, State Public Health Agency/Department.

There could be other state laws/regulations that we would not be aware of with regard to the length of time to maintain records/logs. Again, you should contact your State Board of Dental Examiners/Licensing Board, State OSHA Plan (should the practice be located in a state with their own plan), state/local Environmental Protection Agency (EPA) office, and state/local health agency (health dept.) for all applicable laws in your state.

OSAP provides links to state agencies that may viewed at: http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=71

Resource:

1) OSHA's Bloodborne Pathogens Standard 29 CFR 1910.1030

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

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Q I would like to know how to certify our OSHA training so that it may count toward the new requirements for Continuing Education credits for Dental Hygienists. We have developed a great program, review it upon hire and annually with staff at risk. Do you have any guidance for me?

A Continuing education requirements do vary among states. You should contact your State Board of Dental Examiners/Licensing Board and National/State Dental Hygiene Association for assistance.

The State Board will be able to provide you with OSHA and infection control and continuing education training requirements in your state.

Additionally, the National/State Dental Hygiene Association will be able to provide you with information and assistance on how to submit your training materials for continuing education approval through the Association.

National Dental Hygiene Association: http://www.adha.org

Also, for the certified dental assistants in your practice, you should contact the American Dental Assistants' Association for information on submitting your training materials for continuing education approval.

American Dental Assistants Association: http://www.dentalassistant.org

OSAP provides links to state agencies at: http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=71

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Q What precautions should I take to be safe in a dental setting when pregnant?

A Although OSAP cannot provide specific medical advice concerning potential risk factors and pregnancy, we can provide you with general information. First and foremost, however, pregnant dental health care workers should consult with their primary care physician and/or an obstetrician for medical advice and recommendations. In addition, OSAP is not aware of individual state/local laws/regulations, therefore, the appropriate state/local agencies should be contacted for specific laws (e.g. State Board of Dental Examiners/Licensing agency, State Health Dept., State/local EPA, etc.).

Pregnant workers generally are not considered to be at an increased risk for acquiring infections occupationally. There are, however, some infections, which if acquired by the mother, can cause problems for the developing fetus. Adherence to appropriate infection control precautions, including standard precautions is indicated. Female workers of childbearing age should ensure that they have received all recommended immunizations and consult with their personal physician regarding which immunizations may require booster doses. (1), (2), (3)

The "Guidelines for Infection Control in Health Care Personnel, 1998" provide specific information for precautions for pregnant healthcare workers. (See table 6 located within the document). (1)

First and foremost, all dental health care workers, whether they are pregnant or not, must adhere to and practice Universal/Standard Precautions with all patients, practice sharps safety protocols, follow all directions for safe handling, use, disposal of chemicals, obtain vaccinations recommended by the Centers for Disease Control and Prevention (CDC) (http://www.cdc.gov/ ). These vaccinations include, but are not limited to: Hepatitis B; MMR (measles, mumps, rubella); Varicella (chickenpox vaccine); Td booster (at least every 10 years); and the flu vaccine during flu season (except when contraindicated for medical reasons/pregnancy, generally, a pregnant women should avoid receiving any live vaccine and must always consult with their OBGYN/Healthcare Provider concerning vaccinations and contraindications). (3)

Second, one of the most important and effective procedures to perform to prevent and/or reduce the spread of infection is proper hand hygiene as hands serve as conduits for the transfer of microorganisms, including pathogenic microorganisms. The use of appropriate personnel protective equipment PPE's, especially gloves, mask, protective eyewear, and gown must be worn during procedures where there is the potential for spray, splash, splatter of blood and other potentially infectious materials/fluids, including saliva during dental procedures. (3) (5)

The Centers for Disease Control and Prevention published the revised Infection Control for Dental Health Care Facilities in December 2003. These guidelines may be viewed at:

http://www.cdc.gov/OralHealth/infectioncontrol/index.htm.

Other issues include; exposure to chemicals (e.g. surface disinfectants, sterilants, numerous dental materials, etc.); radiation; and the use of compressed gases (specifically, nitrous oxide). Practice radiology safety protocols, and when indicated or required by State law, wear radiation monitoring film badges and monitor nitrous oxide levels.

Prior to using or working with any chemical be sure to read and follow all manufacturer's instructions and refer to the material safety data sheets (MSDA) for further important information. In addition, be sure to wear the appropriate PPE and work in well ventilated areas.

Radiology safety protocols should be strictly adhered to. All workers must follow precautions to prevent occupational exposure to radiation emitted from dental x-ray machines. Dental health care workers (especially pregnant workers) should consider wearing a monitoring dosimeter film bade on uniforms (waste level) for monthly assessment. In some States this is mandate by Law so always check with your State Board of Dental Examiners/licensing agency and other State agencies responsible for radiation safety. X-ray machines should be monitored/inspected according to all local and/or State laws (usually required on an annual basis). Never stand in the direct path of the x-ray beam (stand at least 6-8 feet away or behind a lead-lined wall) and never attempt to hold film in a patient's mouth during x-ray exposure.

Other precautions include: ensuring the machines are properly collimated, the worker is never present in the room during exposure of the film, the worker is not in the path of the active beam, the proper kVP and MA are utilized, and the highest speed film is used to further reduce the amount of radiation needed to expose the film. Additionally, monitoring exposure through the use of radiation monitoring badges may be considered. (2)

Additionally, if you use nitrous oxide, special precautions are warranted. Adverse effects associated with chronic nitrous oxide exposure in dental healthcare workers have been well documented over the years. Chronic exposure to N20 may include defects such as: nausea, spontaneous abortion/miscarriage, neurological defects, liver/kidney problems anemia, and cancer. NIOSH (National Institute for Occupational Safety and Health) recommends that N20 equipment be inspected, maintained, and a scavenger system be utilized. (4)

In addition, nitrous oxide hoses, connections, patient face mask, and fittings should be routinely checked for leaks, and the room air in the treatment areas should be periodically monitored for excessive levels of nitrous oxide. The supplier of the tanks/gases should be able to provide air monitoring service.

The maximal amount of nitrous oxide allowable in a healthcare setting is 50ppm. For further information on Nitrous Oxide, NIOSH's website is: http://www.cdc.gov/niosh/noxidalr.html

For further information on the effects of workplace hazards go to NIOSH's website at: http://www.cdc.gov/niosh and CDC's occupational health guide at:

http://www.cdc.gov/ncidod/hip/occhealt/ocguide.htm

The National Institute For Occupational Safety & Health also has posted on it's website a great deal of information on: "The Effects Of Workplace Hazards On Female Reproductive Health". This information is located at:

http://www.cdc.gov/niosh/99-104.html

Other information concerning OSHA's Bloodborne Pathogens Standard and Hazardous Communication Standard (hazardous chemicals) may be obtained at OSHA's website at: http://www.osha.gov

OSAP has further information regarding Universal/Standard Precautions, sharp's and safety, and hazardous chemicals on its website at: http://www.osap/org/resources

Resources:

(1) Bolyard EA, Tablan OC, Williams WW, et al. "Guidelines for Infection Control In Health Care Personnel, 1998" AJIC 1998 Jun; 25(3):291-354. Available at:

http://www.cdc.gov/ncidod/hip/guide/infectcont98.htm

(2) OSAP's frequently asked questions: http://www.osap.org/resources/FAQ/index.php?name=9#4


(3) The Centers for Disease Control and Prevention: http://www.cdc.gov and Infection Control Guidelines for Dental Health Care Facilities:

http://www.cdc.gov/OralHealth/infectioncontrol/index.htm.

(4) The National Institute For Occupational Safety & Health: http://www.cdc.gov/niosh

(5) The Occupational Safety & Health Administration:


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