● Establishing a mechanism for post exposure monitoring, follow-up, and post exposure prophylaxis. ● Providing HBV vaccination free of charge to all employees with occupational exposure. ● Monitoring employee work practices and behaviors to ensure compliance. ● Establishing and maintaining the appropriate training and medical records for each employee. ● Ensuring that all items in the office are properly labeled and indicated. (CDC, 2016b) Although originally published in 1992 and updated in 2001, the OSHA Bloodborne Pathogens Standard remains in effect today (OSHA, 2001). All dental personnel should be familiar with all the provisions of this standard. More information on this document can be found in the Resources section of this course. Although published almost two decades ago, the Guidelines for Infection Control in Dental Health-Care Settings – 2003 are still the most current dentistry-specific infection control guidelines from the CDC, and many state boards have adopted them as their infection control regulations. More recently, the increasing number of HAIs and the propagation of many drug-resistant infections occurring in outpatient settings, not to mention the COVID-19 pandemic, have caused the CDC to place more emphasis on infection control in these types of facilities. To help ensure better compliance with infection control recommendations, the CDC produced the Guide to Infection Prevention for Outpatient Settings: Minimum Expectations for Safe Care in May 2011 (updated in 2015 and 2016) (CDC, 2016b). This guide is targeted specifically at outpatient settings and stresses that all healthcare facilities, including dental offices, “must make infection prevention a priority and must be equipped to observe Standard Precautions” (CDC, 2016b). Furthermore, each facility must “ensure that sufficient fiscal and human resources are available to develop and maintain infection prevention and occupational health programs,” inclusive of providing the necessary PPE, hand hygiene products, and other equipment/devices necessary for following the standard precautions shown in Table 1 (CDC, 2016b). Although the guide’s main focus is on medical facilities, the great majority of its directives apply to dentistry as well, which is in fact considered an outpatient setting. Attached to this guide is a very straightforward checklist that can serve as an excellent resource for each dental office to evaluate its infection control compliance (CDC, 2016b). In 2016, the CDC published Summary of Infection Prevention Practices in Dental Settings, which did not replace the 2003 guidelines, but added some topics. The guide includes a checklist for dental offices to use in evaluation of their infection control and prevention practices (CDC, 2016c).
The OSHA Bloodborne Pathogens Standard is enforceable in every state in the U.S., and significant penalties can be levied for lack of compliance. Roughly half the states in the country have state OSHA programs, which are independent agencies that adopt and enforce their own Bloodborne Pathogens Standard. The federal Bloodborne Pathogens Rule serves as the minimum standard, and some states have expanded the regulation to include requirements not found in the federal rule. Each dentist/ employer must be compliant with all the elements of the Bloodborne Pathogens Standard, including: ● Establishing an exposure control plan designed to protect employees with occupational exposure from contacting blood and OPIM. ● BBP training on an annual basis for all employees with occupational exposure. ● Providing and maintaining appropriate PPE and training employees on how it is used properly. Centers for Disease Control and Prevention Although OSHA’s mission is to protect employees in the workplace, the Centers for Disease Control and Prevention (CDC) is tasked with protecting the public health of the entire U.S. population. The CDC is not a regulatory agency, but it does recommend infection control precautions often used to form the basis for regulations set by state licensing boards and OSHA. As cases of HIV/AIDS began to increase in the 1980s, concern about transmission of HIV/AIDS in the dental office began to mount. At that time, infection control in dentistry was rudimentary, contact with blood was frequent, the number of percutaneous exposures was high, the use of barriers was almost nonexistent, and disinfection and sterilization practices were questionable. Accordingly, the CDC published Recommended Infection Control Practices for Dentistry in 1986, but the recommendations were generally ignored by the profession as a whole. However, by the early 1990s and the publication of the Bloodborne Pathogens Standard, most dentists realized that infection control was important for their safety and for the safety of their patients and staff. In order to enable dental professionals to provide oral health care as safely as possible, the CDC published an updated Recommended Infection Control Practices for Dentistry in 1993 (which closely paralleled the Bloodborne Pathogens Standard). This document provided guidance to the dental profession until December 19, 2003, when the CDC published the new, evidence-based, Guidelines for Infection Control in Dental Health-Care Settings – 2003 (CDC, 2003). As new diseases and technologies emerge, new infection control practices must be introduced, and the 2003 CDC guidelines recommended significant modifications and updates in the infection control practices for the dental profession. All dental professionals should be familiar with the infection control principles contained in this document. More information on this document can be found in the Resources section of this course.
CALIFORNIA LAWS
California Dental Practice Act The California Dental Practice Act consists of the basic body of laws governing dentistry found in the California Business and Professions Code (B&P): Division 2, Chapter 4 (beginning with Section 1600), and the California Code of Regulations (CCR): California Department of Consumer Affairs The California Department of Consumer Affairs includes 39 regulatory entities that protect public health and safety through licensing and oversight of various professions. These boards and bureaus establish minimum qualifications and levels of competency for licensure in more than 280 business and professional categories, including all health professions (Department of Consumer Affairs, S. of C., 2021). The Dental Board of California is one such board falling within the purview of the California Department of Consumer Affairs, which
Title 16, Division 10 (beginning with Section 1000). California law requires every dental professional to have a grasp of this basic body of law and related portions of other selected California statutes. provides a variety of key administrative services to these semi- autonomous boards. Board members collectively are the leaders of these licensing agencies, and make important decisions on agency policies and disciplinary actions against professionals who violate state consumer protection laws. Board members approve regulations and help guide licensing, enforcement, public education, and consumer protection activities. Some board members are licensed professionals, whereas others are public members. The
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