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FAQ's Regulatory

Frequently Asked Questions (FAQs) on Dental Infection Control


Top|Regulatory Processes


Frequently Asked Questions for Regulatory Processes


Q Does a written record need to be kept for biological monitoring results?

Q How many years do you keep records of biological monitoring of sterilizers?

Q What Centers for Disease Control and Prevention (CDC) guidelines apply to anesthesiologists?

Q Does an office need two refrigerators—one for medicine and one for biopsies/cultures?

Q When a manufacturer changes a formulation, how soon must the Material Safety Data Sheet (MSDS) be updated?

Q What exactly is the 1999 California-OSHA regulation regarding disposable needles?

Q Which states require weekly biological monitoring and which require monthly?

Q If an office gets flooded, what should be done with supplies?

Q Where can I find a laundry service that can handle contaminated lab coats and gowns service?

Q What are the most current infection control recommendations for handling extracted specimen teeth in dental educational lab settings?

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

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

Q I am a dental hygienist who works part-time in more than one dental office. Does each employer have to provide and launder a smock to be worn when working in that particular office?

Q Does the California Occupational Safety and Health Administration prohibit handscrubbing of instruments before sterilization?

Q How can we ensure that we have the correct number of fire extinguishers and that they are properly maintained?

Q Does OSHA prohibit the passing of sharp instruments between assistant and operator?

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

Q What do I need to do to ensure my office is OSHA-compliant?

Q Should needlestick injuries be reported to the dental workers' compensation carrier?

Q Does OSHA prohibit the use of cuspidors?



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Q Does a written record need to be kept for biological monitoring results?

A Many states require dental offices to maintain records of biological monitoring. Because requirements change frequently and vary from state to state, OSAP recommends that you check with your state licensing agency for requirements at your location. (1).

References:
(1) The Dental Student Network list of state licensing agencies. Available at http://www.studentdoctor.net/dental/state_boards.html

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Q How many years do you keep records of biological monitoring of sterilizers?

A There is no federal requirement for monitoring or recordkeeping. Additionally, many of the states that require monitoring do not have specific requirements for maintaining records. To determine if you are in a state with required monitoring and if the state agency has guidelines on recordkeeping contact your state licensing agency (1). Because recordkeeping can play a role in risk management, it may be wise to consult your practice's attorney for advice on maintaining such records.

References:
(1) The Dental Student Network list of state licensing agencies. Available at http://www.studentdoctor.net/dental/state_boards.html

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Q What Centers for Disease Control and Prevention (CDC) guidelines apply to anesthesiologists?


A The general guidelines for infection control that apply to healthcare workers such as nurses also apply to anesthesiologists. These recommendations include handwashing, environmental asepsis, sterilization and disinfection, postexposure follow-up, and others. All CDC guidelines can be obtained at no charge from the CDC website at http://www.cdc.gov. Recommendations for Infection Control for the Practice of Anesthesiology have been published by the American Society of Anesthesiologists.(1)

References:
(1) American Society of Anesthesiologists. Recommendations for infection control for the practice of anesthesiology. Available at http://www.asahq.org/ProfInfo/Infection/Infection_TOC.html

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Q Does an office need two refrigerators—one for medicine and one for biopsies/cultures?

A If the containers are leakproof and the items are well separated and clearly marked, two refrigerators may not be necessary. Call your state's OSHA office and Department of Public Health for further clarification regarding your state's rules.(1) Food, medications or other consumables should not be stored in the same refrigerator with chemical products or items containing potentially infectious materials such as blood, tissue or saliva.

References:
(1) OSHA. State Occupational Safety and Health Plans. Available at http://www.osha.gov/fso/osp/index.html

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Q When a manufacturer changes a formulation, how soon must the Material Safety Data Sheet (MSDS) be updated?

A If the manufacturer becomes newly aware of a hazard associated with an existing formulation, the label for that product must be revised within 3 months. For new or revised formulations, the labels and MSDS must contain new or revised hazard data when the newly formulated product is shipped. The employer must then update their MSDS directory upon receipt of the new MSDS.(1)

References:
(1) OSHA. 29CFR 1901.1200. Hazard Communication. Available at http://www.osha.gov/SLTC/hazardcommunications/index.html

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Q What exactly is the 1999 California-OSHA regulation regarding disposable needles?

A California now requires the use of devices with engineered sharps injury protection (ESIP). The safety device must have built-in injury protection. Safety needles are not required if the employer-practitioner can show objective information that demonstrates the needles are not safer than the devices and practices currently in use in the practice, the devices are not available in the marketplace, or the devices interfere with the delivery of patient care. Employers must evaluate available devices if no reasonably specific and reliable information is available regarding the clinical use of the devices.(1) Evaluation forms and instructions for their use are available online at the CDC Oral Health website (2).

References:
(1) California Department of Industrial relations. CCR Title 8, Section 5193. Bloodborne Pathogens. Available at http://www.dir.ca.gov/title8/5193.html
(2) http://www.cdc.gov/oralhealth/infectioncontrol/forms.htm

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Q Which states require weekly biological monitoring and which require monthly?

A Alabama, California, Colorado, Georgia, Idaho, Illinois, Iowa, Kansas, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, North Carolina, North Dakota, Ohio, Pennsylvania, South Carolina, Tennessee, and Washington are among the states that require weekly biological monitoring. Among those that require monthly or semi-monthly biological monitoring are Arkansas, Florida, Indiana, Michigan, and Oregon. These requirements are subject to change, so the state licensing agency should be contacted regarding specific requirements in your location.

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Q If an office gets flooded, what should be done with supplies?

A As addressed by Lynne Sehulster, PhD, with the Centers for Disease Control and Prevention's Division of Healthcare Quality Promotion:
Determine the source of the flooding. If it's a leak (e.g., water pipe develops a leak, roof leaks after a heavy rain), stop the leak and make the repair. If the flooding is from a natural event, remove the water or allow it to recede.
Determine if the potable tap water supply has been compromised. Check with the municipal water utility for more guidance if the problem comes from natural flooding. Comply with "boil water" advisories(1) issued by local authorities. If the flooding comes from a plumbing leak in the building, the plumber should be able to advise you as to whether water quality will be restored after the leak is repaired. Note: The importance of restoring water quality early on is to help with the rest of the operatory clean up.
With regard to operatory equipment, instruments, and supplies, discard any disposable, single-use items that have become wet. Reuseable supplies, packaged or unpackaged, should be cleaned with clean, potable water and reprocessed according to manufaturer recommendations. If water quality cannot be readily restored, use bottled water (such as you would find in the supermarket) for this purpose. Equipment should be cleaned up as much as practical. If electrical equipment is water-damaged, check with the manufacturer to obtain its recommendations for cleaning and restoring safe operation.
Clean hard, non-porous environmental surfaces (e.g., floors) with clean water and a detergent disinfectant. Clean and then disinfect operatory surfaces such as the countertops using a low- or intermediate-level disinfectant.
Dental/medical records should be dried out and copies made if needed. If records are contaminated (e.g., from a major sewage spill) and they can't be copied, then laminate the page or surround it with plastic wrap. Check with local hospitals to see what methods might be available to for record restoration and preservation.
Structural damage to walls, floors, ceilings, etc. from major flooding should be addressed ASAP. To prevent the growth of mold and mildew, wet sheetrock, plasterboard, carpeting, and any other absorbent building material needs to be thoroughly dried out within 72 hours. If this is not feasible, then those wet materials need to be removed to allow the underlying structure to dry. It may help to have an engineer or a health department industrial hygienist come by with a moisture meter to make the determination of "dryness."
Additional OSAP resources on managing flood conditions.

References:
(1) CDC. Suggested procedures for dental offices during boil-water advisories. Available at http://www.osap.org/issues/news/index.php?name=969375729

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Q Where can I find a laundry service that can handle contaminated lab coats and gowns service?

A Try contacting local hospitals or large medical clinics to ask if they use a professional service for contaminated laundry.

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Q What are the most current infection control recommendations for handling extracted specimen teeth in dental educational lab settings?

A The Centers for Disease Control and Prevention (CDC) addressed this issue inGuidelines for Infection Control in Dental Health-Care Settings, 2003.(1) They state the following: "Extracted teeth that are being discarded are subject to the containerization and labeling provisions outlined by OSHA's bloodborne pathogens standard. OSHA considers extracted teeth to be potentially infectious material that should be disposed in medical waste containers. Extracted teeth sent to a dental laboratory for shade or size comparisons should be cleaned, surface-disinfected with an EPA-registered hospital disinfectant with intermediate-level activity (i.e., tuberculocidal claim), and transported in a manner consistent with OSHA regulations. However, extracted teeth can be returned to patients on request, at which time provisions of the standard no longer apply. Extracted teeth containing dental amalgam should not be placed in a medical waste container that uses incineration for final disposal. Commercial metal-recycling companies also might accept extracted teeth with metal restorations, including amalgam. State and local regulations should be consulted regarding disposal of the amalgam."

Additionally, extracted teeth should be cleaned and then decontaminated with a suitable disinfecting or preserving agent.(1,2) Extracted teeth without amalgam fillings may be autoclaved. (Teeth containing amalgam should never be heat sterilized because the high temperatures of the sterilization cycle can release mercury vapor.)(2,3). Extracted teeth may be given to the patient or may be used in an educational setting once proper decontamination procedures have been conducted.

References:
1) CDC. Guidelines for Infection Control in Dental Health-Care Settings --- 2003. December 19, 2003 MMWR 52(RR17);1-61 http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm

2) Tate WH, White RR. Disinfection of human teeth for educational purposes. J Dent Educ 1991;54(5):583-5.

3) Cuny E, Carpenter W. Extracted teeth: decontamination, disposal and use. CDA J 1997;25(11):801-4.

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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://www.studentdoctor.net/dental/state_boards.html.

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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://www.studentdoctor.net/dental/state_boards.html.

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Q I am a dental hygienist who works part-time in more than one dental office. Does each employer have to provide and launder a smock to be worn when working in that particular office?

A Your job puts you at risk for exposure to blood and other potentially infectious materials, which, according to the Occupational Safety and Health Administration (OSHA), includes saliva. The OSHA Bloodborne Pathogens Standard requires that appropriate personal protective attire be provided at no cost to you by your employer. If you have more than one employer at different worksites, each employer must provide appropriate protective attire in the proper size. Employers also are responsible for maintaining personal protective equipment, including laundering and replacing as needed.(1).

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

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Q Does the California Occupational Safety and Health Administration prohibit handscrubbing of instruments before sterilization?

A According to infection control experts in California, Cal/OSHA does not specifically prohibit handscrubbing of instruments, nor does it recommend or specifically approve the practice.

OSAP is not aware of any state OSHA program that specifically prohibits this practice. For more information, contact your state OSHA office.

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Q How can we ensure that we have the correct number of fire extinguishers and that they are properly maintained?

A Federal, state, and local laws apply to fire safety. OSHA has a Fire Safety Standard, and states and localities have their own fire codes.

The number of required mounted fire extinguishers is typically based on square footage of the office. For details, contact your local fire department.

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Q Does OSHA prohibit the passing of sharp instruments between assistant and operator?

A OSHA does not specifically prohibit the passing of sharps, although it does require that engineering controls and safe work practices be in place.

The use of sharps with engineered safety features that reduce the risk of injury is an example of an engineering control. Announcing instrument passes and completing them with the sharp ends pointing away from both the passer and the receiver is an example of a work practice control.(1,2,3)

References:
(1) OSAP Issue Focus: Needle and sharps safety.
(2) OSHA. Safety and Health Page for Needle Sticks. Available at http://www.osha-slc.gov/Publications/osha3161.pdf
(3) NIOSH. What every worker should know; how to protect yourself from needlestick injuries. Available at http://www.cdc.gov/niosh/2000-135.html.

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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 What do I need to do to ensure my office is OSHA-compliant?

A A number of checklists are available to guide compliance efforts in the dental practice, including the comprehensive OSAP checklist published in the April 2003 edition of Infection Control In Practice. The OSAP checklist incorporates all regulations and recommendations that apply to dental infection control and safety, not just Occupational Safety and Health Administration (OSHA) mandates. While checklists can help to guide and organize a practice compliance activities, OSHA states that checklists or other similar guides are not considered a substitute for any provisions of the Occupational Safety and Health Act or for any standards issued by OSHA. It is the standards themselves that are the legal requirements to which an employer is held, so it in your best interest to read them in their entirety. The federal OSHA Standards that relate to dentistry include:

Bloodborne Pathogens Standard, Hazard Communication Standard,
the
the Formaldehyde Standard,
the standard on Personal Protective Equipment,
and the Nitrous Oxide Standard.
If you practice in a state with its own OSHA Plan, contact the state OSHA office for additional regulations that may apply to your state.

Some dental practitioners contract a private dental consultant to perform a comprehensive assessment of the office for a fee. Contact your state/local dental societies for recommendations if you are interested in obtaining this service.

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Q Should needlestick injuries be reported to the dental workers' compensation carrier?

A As a rule, injuries that require medical evaluation, care, and/or treatment to workers must be reported to workers' compensation carriers. However, workers' compensation programs can vary from state to state. Contact your state office of employment or worker's compensation for details of how these injuries should be handled.

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Q Does OSHA prohibit the use of cuspidors?

A While OSHA does not prohibit the use of cuspidors, they do pose infection control concerns. Patient materials are continually expelled into the basin, so cuspidors are continually contaminated. For this reason, many practices have opted to eliminate them, instead using high-volume evacuation (HVE, "suction”) to clear away oral fluids.

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