Remember the importance of adhering to your infection control procedures. OSHA standards for sterilization in the medical setting have been set forth to protect patients and office personnel from being exposed to blood or other potentially infectious materials. OSHA requirements are set by statute, standards, and regulations, which when followed will provide protection. Unfortunately these standards and regulations are not always followed.
Back in March 2013, a news story surfaced stating that about 7,000 patients who visited a suburban Tulsa, Oklahoma oral surgeon in the past six years may have been exposed to HIV and hepatitis, according to health investigators. The state health department then started to contact these patients urging them to be tested for hepatitis B, Hepatitis C, and HIV. As reported by the ADA News, "This is the first documented report of patient-to-patient transmission of hepatitis C virus associated with a dental setting in the United States," said Oklahoma state epidemiologist Kristy Bradley, D.V.M. While dental procedures are generally safe, this reinforces the importance of adhering to strict infection control procedures in dental settings.
According to the complaint, the violations included multiple sterilization issues, multiple cross-contamination issues. There were no logs of inventory for the drug cabinet, and it was left unlocked and unattended. One drug found in the cabinet had expired in 1993. Other records showed that morphine had been used in patients throughout 2012, even though the doctor had not received a morphine delivery since 2009. The complaint goes on to state that the doctor's dental assistants did not have permits. The executive director for the Oklahoma State Board of Dentistry mentioned that "the doctor allowed "unauthorized, unlicensed" employees to perform intravenous sedation of patients." The doctor also told officials that he left questions about sterilization and drug procedures to his employees. The state dentistry board quoted the doctor as saying, "They take care of that, I don't." This office wasn't practicing universal/standard precautions and the state dental board branded the dentist a menace to public health.
As of September, 2013, the Oklahoma Public Health Laboratory completed testing for 4,202 persons. Eighty-nine patients tested positive for hepatitis C, five for hepatitis B, and four for HIV. An unknown number of patients sought testing through private health care providers. Based on current Oklahoma disease prevalence data for hepatitis B and C and HIV, health officials recognized some of the screening results would be positive for infection unrelated to dental procedures at the practice they are investigating.
Although a rare occurrence, this example demonstrates a practice that chose not to follow appropriate guidelines/protocols. OSHA's bloodborne pathogen standard states: In order to reduce or eliminate the hazards of occupational exposure to bloodborne pathogens, an employer must implement an exposure control plan for the worksite with details on employee protection measures. The plan must also describe how an employer will use a combination of engineering and work practice controls, ensure the use of personal protective clothing and equipment, provide training , medical surveillance, hepatitis B vaccinations, and signs and labels, among other provisions."[29 CFR 1910.1030(c)(1)(iv)].
OSHA standards also support a workers' right to a safe workplace. The law requires employers to provide their employees with working conditions that are free of known dangers. The highest standards of clinical care were not followed in the case study above, and the patients' interests were compromised. Adherence to the procedures and standards as set forth will provide workers and patients protection from exposure.
If you ever have any questions or concerns regarding exposure control, please make sure to contact us so that we can assist you. A great resource is our online Hazard Risk Assessment. As you know, under OSHA regulations, practices are required to complete a hazard risk assessment to identify the hazards that are present in their workplace environment. You must identify the hazards in your workplace that require the use of personal protective equipment "PPE". If you need assistance with accessing or completing your Hazard Risk Assessment please reach out to us via email or phone.