Many dental practices assign a clinical staff member, often a dental assistant or hygienist, to serve as the office’s compliance officer or compliance manager. Typically, the primary duties of this position are to:
- make sure that staff is aware of the various federal agencies that issue infection control guidelines
- provide an explanation of what each agencies’ mission is and why it’s involved in creating and enforcing rules on infection control
- regularly compare the practice’s current infection control plan and procedures to federal and state guidelines to ensure compliance
- The Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens and Hazard Communications Standards offers a sample policy and a template that practices can fill in to help ensure their plans and procedures are both current and compliant.
- The model plan in that resource has not been updated to include information on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS); details on that are available in the OSHA Fact Sheet on the Hazard Communication Standard Final Rule.
- The GHS is expected to prevent injuries and illnesses, save lives and improve trade conditions for chemical manufacturers.
- The Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens and Hazard Communications Standards offers a sample policy and a template that practices can fill in to help ensure their plans and procedures are both current and compliant.
- download and distribute the appropriate infection control checklists from the Centers for Disease Control and Prevention (CDC), including the Infection Prevention Checklist for Dental Settings, and make sure staff is aware of how to use them and why it’s important to do so
- develop customized written plans to ensure the practice is compliant with all applicable guidelines and regulations
- help ensure that each member of the dental team receives annual training on infection control procedures and protocols
- keep training records that document:
- the date(s) of the training session(s)
- a listing of the topics covered during the training or a summary of the program
- the names and qualifications of whomever conducted the training
- the names and job titles of everyone who attended the session
- maintain that documentation for at least three years
- keep training records that document:
- indicate which specific tasks are assigned to which individual employees and make sure that those tasks are competed properly
- use CDC’s Infection Prevention Checklist for Dental Settings: Basic Expectations for Safe Care to help make sure the practice is in compliance
- help make sure everyone in the practice adheres to the current OSHA standard for Tuberculosis
- develop a post-exposure plan and ensure that it’s followed if needed
- make sure that all members of the team know how to contact the designated health provider to conduct post-exposure follow-up medical care
- the practice must maintain any exposure records according to the requirements of the appropriate federal or state regulations and follow whichever rules are most stringent
- Refer to the ADA Tip Sheet on Exposure Control Plans and the ADA Sample Exposure Control Checklist, which is included as a Resource in this module, which appears courtesy of the ADA Practical Guide to OSHA Compliance Manual, for more information about what should be included in the practice’s written exposure control plan.
Resources:
- OSHA Bloodborne Pathogens and Hazard Communications Standards [PDF]
- OSHA Fact Sheet on the Hazard Communication Standard Final Rule
- CDC Infection Prevention Checklist for Dental Settings: Basic Expectations for Safe Care [PDF]
- OSHA Standard for Tuberculosis
- ADA Tip Sheet on Exposure Control Plans [PDF]
- ADA Sample Exposure Control Checklist [PDF]
- ADA OSHA & Infection Control products [ADA Store]
- CDC Q&A on Personal Protective Equipment
-
OSHA’s Most Frequently Asked Questions Concerning the Bloodborne Pathogens Standard