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TABLE OF CONTENTSHEPATITIS B VACCINATION AND ANTIBODY TESTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22-23Hepatitis B Vaccine Declination Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24POST-EXPOSURE EVALUATION AND FOLLOW-UP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25-26Occupational Exposure Incident Report Form Sample . . . . . . . . . . . . . . . . . . . . . . . . . . . 27For Use in this Dental Office . . . . . 28COMMUNICATION OF HAZARDS TO EMPLOYEES AND TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Labels and Signs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Information and Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30-31OSHA Bloodborne Pathogens Standard Training Record . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Sample . . . . . . . . . . . . . . . . . . . . . . . . . . . 32For Use in this Dental Office . . . . . 33RECORD KEEPING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34EVALUATION AND REVIEW OF EXPOSURE CONTROL PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35APPENDIX (Reference Materials) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a1Employer Reference Pages . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a1-12Employer Liability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a1-3Employer Rights at the Time of an OSHA Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a4Employer — Frequently Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a5Useful Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a6Web Sites for Referential Documents/Other Helpful Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a7Needle Safety Amendments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a8-9State and Federal Poster Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . a10-12WDA WEB SITE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .MEMBERSHIP SERVICES SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .a13a14OSHA Bloodborne Pathogens Manual can be accessed from the WDA Web site, www.wda.orgWDA updates made in 2008OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAiii

WDA DISCLAIMERThis OSHA Exposure Control Plan has been developed by the WisconsinDental Association, in conjunction with Dr. Elise Sampson (MarquetteUniversity School of Dentistry), and is provided for informationalpurposes only. It should not be construed or understood as legal adviceon any specific issue or issues. The contents of this publication are generalin nature and cannot be relied upon for guidance in specific situations.You (the employer) should consult with your attorney to determine howmatters discussed in this plan may relate to your practice or situation.THE WISCONSIN DENTAL ASSOCIATION, INC. MAKES NOREPRESENTATION OR WARRANTY, EITHER EXPRESSED ORIMPLIED, WITH RESPECT TO THIS PLAN AND DOES HEREBYEXPRESSLY DISCLAIM ANY AND ALL WARRANTIES AS TO THEACCURACY OF THE CONTENTS OF THIS MATERIAL, ITSAPPLICABILITY TO ANY SPECIFIC CIRCUMSTANCES ORSITUATION, OR ITS APPLICABILITY OR VALIDITY IN ANYPARTICULAR JURISDICTION. The Wisconsin Dental Association,Inc. expressly disclaims any and all:i) responsibility for opinion(s) expressed by the author and anyinaccuracies, errors or omissions contained in these materials;ii) obligation to revise or update these materials at anytime inthe future.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 1

EXPOSURE CONTROL PLAN, PURPOSE AND ADMINISTRATIONPURPOSE(Dental Office/Practice/Facility Name)is committed to providing a safe and healthful work environment for our entire staff.In pursuit of this endeavor, the following Exposure Control Plan is provided to eliminateor minimize occupational exposures to bloodborne pathogens in accordance withOSHA Standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens”.The Exposure Control Plan is a key document to assist this dental office/practice/facilityin implementing and ensuring compliance with The Standard, thereby protecting ouremployees.ADMINISTRATIONDirections: The spaces below are to be completed by either the employeror assigned staff person.____________________ is in charge of the implementation of this Exposure Control Plan.________________________ will maintain, review, and update the Exposure Control Planat least annually, and whenever necessary to include new or modifiedtasks and procedures.________________________ will ensure that those employees who are determined to haveoccupational exposure to blood or other potentially infectious materialswill comply with the procedures and work practices outlined in thisExposure Control Plan.________________________ will maintain and provide all necessary personal protective equipment,engineering controls (e.g., sharps containers), labels, and red bags asrequired by the Standard.________________________ will ensure that adequate supplies of the aforementioned equipment areavailable in the appropriate sizes.________________________ will ensure that all medical actions required are performed and thatappropriate employee health and OSHA records are maintained.________________________ will conduct training, will maintain documentation of training and willprovide the written Exposure Control Plan available to employees.________________________ will provide the written Exposure Control Plan to OSHA,and NIOSH representatives.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 2

INSTRUCTIONS FOR EXPOSURE CONTROL PLAN USEPLEASE READ CAREFULLY!CHECKBOXESThe authors strongly recommend that the following individuals…THE EMPLOYER(S)The person(s) ultimately responsible for assuring full compliance of the requirements of theBloodborne Pathogens Standards.AND THE ASSIGNED STAFF PERSON(S)The person(s) delegated to implement portions of this Exposure Control Plan.…read each statement very carefully, before placing a checkmark in the boxes provided. It is essentialthat you are certain the procedure indicated in each statement is being followed in your dentaloffice/practice/facility.TO ENSURE COMPLIANCE IT IS STRONGLY RECOMMENDED THAT YOUPROVIDE STATEMENTS IN THE SPACES GIVEN AND CHECK EACH BOXTHAT APPROPRIATELY DESCRIBES YOUR OFFICE'S PRACTICES.Please be honest and DO NOT check the boxes that do not reflect your office policies, proceduresand standards. It is imperative, however; that by evaluating the boxes left unchecked that yourdental office/practice/facility take steps to be able to check all boxes and ultimately come into fullcompliance with all portions of the plan.EXPOSURE CONTROL PLAN (ECP) SPACESThere are multiple spaces that must be filled in with the name(s) of the employer(s) and/or assignedstaff person(s). (These spaces must be filled in with the name(s) of the appropriate person(s) in youroffice/practice/facility.)ECP AVAILABILITY TO EMPLOYEESOnce reviewed by the employer(s) and assigned staff person(s) this Exposure Control Plan shall be madeavailable to employees in this dental office/practice/facility who are at risk of exposure to blood or otherpotentially infectious materials.ECP FORMSAll forms are located within its corresponding section (e.g. Needlestick Safety and Prevention formis in the Needlestick Safety and Prevention section). Sample forms demonstrate the correct way tocomplete each form. Original forms are provided for the dental office/practice/facility to duplicate,complete and update when needed.APPENDIXContains materials that are intended to supplement the contents of this manual. These materials are notpart of the OSHA exposure control plan.The appendix is provided for additional information that mightassist in clarifying procedures, or which may provide additional informational resources, as well as offerdental specific recommendations. This material is very useful and should be read and utilized accordingly.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 3

EXPOSURE DETERMINATIONDEFINITIONOSHA requires employers to perform an exposure determination toidentify which employees may incur occupational exposure to bloodand/or other potentially infectious materials. The exposure determinationis made without regard to the use of personal protective equipment.Employees are considered to be at risk for exposure even if they wearpersonal protective equipment. An exposure determination has beendeveloped for this dental office/practice/facility by listing all jobclassifications in which all employees may be expected to incuroccupational exposure, regardless of frequency.EMPLOYER PAGEATTENTIONOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 4

EXPOSURE DETERMINATION FORMDental Office/Practice/Facility Name:Address:Dr. Doe Dental000 Apple StreetAny Town, USA 12345Dr. John Doe and Dr. John SmithEmployer Name(s):must acknowledge their responsibility to provide all employees who perform taskswhich could potentially place them at risk for occupational exposure to bloodand/or other potentially infectious materials with full protection as stated in theOSHA Bloodborne Pathogens Standard 29 CFR part 1910.1030.FORM1sThis exposure determination has been made without regard to the use of personal protective equipment.DentistsDental HygienistsLab Technicians/OtherReceptionistJOB CLASSIFICATIONList all job classifications in which employees haveoccupational exposure in this office/practice/facilityDental AssistantsDental Intern*List job classifications in which some, not all, employees,have occupational exposure in this office/practice/facilityTASKS AND PROCEDURES IN WHICH OCCUPATIONAL EXPOSURE WILL OCCUROperatory cleanup procedures including cleaningand processing instruments, disinfection of allcontaminated surfaces and replacement of paperand plastic drapes.These duties are performed byreceptionist when dental assistant is on vacation.SAMPLE* If this person is an unpaid student he/she is not covered by the OSH Act (OSHA). However, for liability purposes, it is wise to include them in your program.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 5

EXPOSURE DETERMINATION FORMFor use in this dental office/practice/facilityDental Office/Practice/Facility Name:Address:Employer Name(s):must acknowledge their responsibility to provide all employees who perform taskswhich could potentially place them at risk for occupational exposure to bloodand/or other potentially infectious materials with full protection as stated in theOSHA Bloodborne Pathogens Standard 29 CFR part 1910.1030.This exposure determination has been made without regard to the use of personal protective equipment.FORM1List all job classifications in which employees haveoccupational exposure in this office/practice/facilityFORUSE INOFFICEList job classifications in which some, not all, employees,have occupational exposure in this office/practice/facilityJOB CLASSIFICATIONTASKS AND PROCEDURES IN WHICH OCCUPATIONAL EXPOSURE WILL OCCUROSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 6

METHODS OF IMPLEMENTATION AND CONTROLUNIVERSAL PRECAUTIONSOSHA Definition…“Universal Precautions” is an approach to infection control…all human blood and certain human bodyfluids are treated as if known to be infectious for HIV, HBV, HCV and other bloodborne pathogens.In this Dental Office/Practice/Facility, since medical history and examination cannot reliablyidentify all patients with Hepatitis B, C, HIV infection and/or other bloodborne pathogens, bloodand body fluid precautions are consistently used for all patients and when handling contaminatedinstruments, equipment, appliances, waste (regulated and other) and laundry.EXPOSURE CONTROL PLANEMPLOYEE RIGHTSIn this Dental Office/Practice/Facility: Employees covered by the Bloodborne Pathogens Standard receive an explanation of this ExposureControl Plan during their initial training session.This Exposure Control Plan is reviewed in employee’s annual training. Employees have an opportunity to review this plan at any time during their work shifts by contacting(Name of assigned staff person) If requested, I/we, the employer, will provide an employee with a written copy of this Exposure ControlPlan free of charge and within 15 days of the request.EMPLOYER RESPONSIBILITIESDirections: The spaces below are to be completed by either the employeror assigned staff person.EMPLOYER PAGEATTENTION ________________________ will review and update the Exposure Control Plan on annualbasis. Annual update of documentation will also include anassessment of technology changes that can reduce exposures. ________________________ will review and update the Exposure Control Plan more frequently,if necessary, to reflect any new or modified tasks and procedures. ________________________ will review and update the Exposure Control Plan to reflect new orrevised employee positions with occupational exposure.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 7

ENGINEERING AND WORK PRACTICE CONTROLSIn this Dental Office/Practice/Facility:Engineering and work practice controls are utilized to eliminate or minimize exposure of employeesas follows:A. SHARPS CONTAINERS Sharps containers are closeable, labeled with the BIOHAZARD symbol (see page 29), punctureresistant, leak proof on the sides and bottom and designed so that employees cannot reach into theopening and be injured by the contents.Directions: Please complete spaces below with the name of the appropriate assignedstaff person. Please be sure the name corresponds with the statement. ______________________________ will ensure that sharps containers are inspected according to theschedule listed below.They are inspected: daily weekly Other:(Please specify) ______________________________ will ensure that when filled to the required safety level, the sharpscontainers are closed, made ready for pick-up, transported ormailed to an appropriate storage site and replaced.Storage site: room #__________________________________REGULATED WASTE SERVICEName of Waste Service:Address:Phone:Pick up Schedule: ___/____/___ ___/____/___ ___/___/____ ___/___/______/____/___ ___/____/___ ___/___/___ ___/___/___B. OTHER ENGINEERING CONTROLSWhenever possible, procedures are conducted in a manner which minimizes splashing,spraying, splattering and generation of droplets of blood or other potential infectious materialsby appropriate use of: Rubber dams High volume suction Saliva ejectors Other:(Please Specify)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 8

ENGINEERING AND WORK PRACTICE CONTROLS CONTINUEDIn this Dental Office/Practice/Facility:C. PROGRAM TO SELECT AND EVALUATE SAFER MEDICAL DEVICESThe revision of OSHA Bloodborne Pathogens Standard “Needlestick Safety and Prevention Act”(PL 106-430) requires employers to identify and make use of effective and safer medical devices for dentaloffices (this largely refers to the review of safer needles or injection devices used in providing dental care)with the intention of reducing or eliminating worker exposure.Several sources of information are available for identifying and evaluating the appropriateness of newdevices with engineering safety features. These include, but are not limited to, searching the Internet,reviewing dental and other literature and reviewing new products at professional meetings.This Dental Office/Practice/Facility solicits input from employees on safety devices as follows: Employees are actively encouraged to solicit and review current information on new safety devicesas it becomes available.Employees meet: quarterly annually as per office calendarto review sharps (needles etc..) and/or sharp instruments with engineered sharps injury protection thathave become available during this time period. If appropriate, recommendations will be made to theemployer as to the selection of the alternative devices.Please note:• Employees are required to meet at least annually.• Small offices may discuss and make recommendations on a moreinformal basis.• A dental office should only consider needlesafe devices that have been firsttested and approved by both the Food and Drug Administration (FDA) andthe American Dental Association (ADA). FDA and ADA approved devicescan then be further evaluated by dentists and staff for potential use withinindividual offices. (Please see page a8 for a list of suggested criteria fordental offices to use when evaluating a needlesafe device.)This exposure control plan is reviewed annually to reflect new instruments and/or equipment now inuse in this dental office/practice/facility as the result of the Needlestick Safety and Prevention Act. Solicitation of input from employees is documented in this exposure control plan by completing theNeedlestick Safety and Prevention Act Form (see page 10-11).OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 9

NEEDLESTICK SAFETY AND PREVENTION ACT FORMListed below are the employees involved in selecting, disseminatingand collecting data relative to the following new safety devices.EMPLOYEE NAMEJane DoeJohn SmithPOSITION/TITLEDental HygienistDental AssistantFORMDescribe the process whereby input is requested:Annual meetings in which employees discuss alternative safety deviceswith the employer.Meeting date(s): ___________ 4/2006 ___________ 4/2007 ___________ 4/2008 ___________ ___________Minutes of Meeting(s)xAttached to this form Other:(Please Specify)Copies of documents used to request employee participationx Attached to this form Other:(Please Specify)Records of responses received from employees to the employer(s)(Such as reports evaluating effectiveness of a safer device)x Attached to this form Other:(Please Specify)2sSAMPLEOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 10

NEEDLESTICK SAFETY AND PREVENTION ACT FORMFor use in this dental office/practice/facilityListed below are the employees involved in selecting, disseminating,and collecting data relative to the following new safety devices.EMPLOYEE NAMEPOSITION/TITLEFORMDescribe the process whereby input is requested:2Meeting date(s): ___________ ___________ ___________ ___________ ___________Minutes of Meeting(s) Attached to this form Other:(Please Specify)Copies of documents used to request employee participation Attached to this form Other:(Please Specify)Records of responses received from employees to the employer(s)(Such as reports evaluating effectiveness of a safer device) Attached to this form Other:(Please Specify)FORUSE INOFFICEFORUSE INOFFICEReminder: Don’t forget to attach the actual documents that have been indicated on the checkboxes.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 11

ENGINEERING AND WORK PRACTICE CONTROLS CONTINUEDIn this Dental Office/Practice/Facility:D. WASHING FACILITIES Washing facilities are available and readily accessible to all employees. Hands are washed thoroughly with warm water and the anti-microbial soap solution provided for thispurpose immediately after removal of gloves. Other skin areas are washed immediately or as soon as feasible after being contaminated with bloodor other potentially infectious materials.E. DISPOSABLE SHARPSRecapping Needles-Rationale and Procedure:In dentistry, administering incremental doses of anesthetic to the same patient is often necessaryand local anesthetic syringes are reusable when used on the same patient during a single dentalappointment. It is necessary, therefore, to recap needles between use and to remove needles fromthe syringe after of each patient’s treatment.Handling and disposal of needles without strict compliance with the followingprotocol can lead to serious exposure to blood and other potentially infectious materials. Employees have been trained to perform these procedures safely and in accordance with OSHABloodborne Pathogens Standard. Contaminated needles are uncoupled from syringe and immediately disposed of in the sharpscontainers provided for this purpose. Sharps containers are located as close as possible to the site of use. Contaminated needles are never bent, sheared or purposely broken.Needle recapping is performed: by the one-handed scoop methodOR by using mechanical devicesOR Other:(Please specify)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 12

ENGINEERING AND WORK PRACTICE CONTROLS CONTINUEDIn this Dental Office/Practice/Facility:F. OTHER CONTAMINATED DISPOSABLE SHARPSContaminated disposable sharps such as scalpel blades, suture needles, broken instruments,broken glass, orthodontic wires and anesthetic carpules (which may cause injury and thereforeexposure to blood if broken) are handled as follows: Broken carpules (scalpel blades, suture needles, broken instruments, broken glass, orthodonticwires and anesthetic carpules) are picked up with forceps or brush and pan and placed immediatelyin the sharps container. Other:(Please specify)G. REUSABLE SHARPSMany reusable dental instruments and appliances used in dentistry are sharp and, if handledimproperly, can cause injury and exposure to blood and other potentially infectious materials.To avoid potential injury when handling these instruments and appliances these proceduresare followed: During treatment that requires the use of reusable sharps (e.g., explorers, excavators, endonditcinstruments), instruments are passed to the assistant/operator in a firm and deliberate manner. Work surfaces are organized to minimize accidental injury with sharps. Sharp instruments are within the full vision of the individual who is reaching for them. After patient treatment and during clean-up, contaminated instruments are always handled withheavy-duty gloves. Instruments are removed from the ultrasonic cleaner by lifting them from the basket. Other:(Please specify)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 13

ENGINEERING AND WORK PRACTICE CONTROLS CONTINUEDIn this Dental Office/Practice/Facility:H. WORK AREA RESTRICTIONSEating, drinking, applying makeup or lip balm, smoking or handling contact lenses isprohibited in all areas where there is potential for contamination with blood or other potentiallyinfectious materials.The above activities may not be conducted in the following areas:For example: Patient Treatment Rooms Laboratories Sterilizing Room Other:(Please specify)The activities listed above (e.g., eating, drinking) are allowed in the following areas of this dentaloffice/practice/facility:______________________ ______________________ _____________________________________________ ______________________ _______________________ Food and beverages are not kept in refrigerators, freezers, shelves, cabinets or on counter tops or benchtops where blood or other potentially infectious materials are present.Food and beverages may be safely stored in the following areas in this dental office/practice/facility:______________________ ______________________ _____________________________________________ ______________________ _______________________OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 14

ENGINEERING AND WORK PRACTICE CONTROLS CONTINUEDIn this Dental Office/Practice/Facility:I. IMPRESSIONS/APPLIANCES/EQUIPMENT ETC. Universal precautions are used at all times whenever handling anything contaminated with bloodor other potentially infectious materials. It is not necessary therefore to label impressions and/orappliances, etc. when handling and transporting them within this dental office/practice/facility. All materials (impressions, appliances, etc.) are decontaminated (see below) before entering theoffice in-house laboratory. All materials (impressions, appliances, etc.) are decontaminated (see below) before packaging forshipping to an outside laboratory.Decontamination method used: 1) Rinse away saliva and debris with running waterAND 2) Immerse inOR 2) Spray with(Name of the disinfectant used and immersion time as per package instructions)(Name of the disinfectant used and contact time as per package instructions) Equipment, which has been contaminated with blood or other potentially infectious materials, isdecontaminated before servicing or shipping. Contaminated equipment, which cannot be decontaminated before servicing or shipping, will beidentified with a biohazard-warning label. (See page 29)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 15

PERSONAL PROTECTIVE EQUIPMENTThe personal protective equipment used in this dental office/practice/facility is consideredappropriate because it does not permit blood or other potentially infectious materials to passthrough or reach employees’ work or street clothing, skin, eyes, mouth or other mucous membranesunder normal conditions of use and for the duration of time which the protective equipment is used.Directions: The spaces below are to be completed with the employer’s name. ________________________ shall ensure that employees use personal protective equipmentappropriate to the task being performed.(Unless the employer shows that the employee temporarily and brieflydeclined to use Personal Protective Equipment when under rare andextraordinary circumstances, it was the employee’s professional judgmentthat in the specific instance its use would have prevented the delivery ofhealth care and public safety services and posed an increased hazard tothe safety of the worker or co-worker. When the employee makes thisjudgment, the circumstances shall be investigated and documented inorder to determine whether changes can be instituted to prevent suchoccurrences in the future.) ________________________ shall ensure that appropriate personal protective equipment is issuedwithout cost to employees. ________________________ shall ensure that employees remove personal protective equipmentafter it becomes contaminated in such a way as to avoid skin contactwith the outside surface. ________________________ shall ensure employees remove personal protective equipment beforeleaving the work area.EMPLOYER PAGEATTENTIONDirections: The spaces below are for the employer’s or assigned staff person’s name. ________________________ shall ensure that suitable personal protective equipment is availablein suitable sizes. ________________________ shall ensure that personal protective equipment is readily accessibleat the work site. ________________________ shall ensure that hypoallergenic gloves, glove liners, powder-freegloves or other similar alternatives are readily accessible to thoseemployees who are allergic to the gloves normally provided.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 16

PERSONAL PROTECTIVE EQUIPMENT CONTINUEDIn this Dental Office/Practice/Facility:A. GLOVES SINGLE-USE GLOVES are worn at all times where it is reasonably anticipated that employees willhave hand contact with blood or other potentially infectious materials, non-intact skin and/or mucousmembranes; when performing vascular access procedures and when laundering or touchingcontaminated items or surfaces. These gloves are replaced as soon as practical when they becomecontaminated or as soon as their ability to function as a barrier is compromised. These gloves are notwashed or decontaminated for reuse. REUSABLE GLOVES (heavy duty, utility gloves) are worn when cleaning and decontaminatingpatient treatment areas; transporting and cleaning contaminated instruments after patient treatmentis completed. REUSABLE GLOVES are used for cleaning and decontaminating lab areas. REUSABLE GLOVES are decontaminated for re-use provided the integrity of the glove is notcompromised. Utility gloves are discarded if they are cracked, peeling, torn, punctured or exhibit othersigns of deterioration or when their ability to function as a barrier is compromised ALL GLOVES are provided for use in the appropriate size for the user. All employees with allergies to the glove material or powder inside the glove are provided withpowder-free and/or non-allergenic gloves and/or glove liners.B. EYE AND FACE PROTECTION Masks, in combination with eye protection devices such as goggles or glasses with solid side shields orchin-length face shields, are required to be worn whenever splashes, spray, splatter or droplets of bloodor other potentially infectious materials may be anticipated.C. PERSONAL PROTECTIVE CLOTHING Protective clothing is worn whenever it is reasonably anticipated employees’ work clothes,street clothes, undergarments or skin may become contaminated with blood or other potentiallyinfectious materials.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 17

PERSONAL PROTECTIVE EQUIPMENT CONTINUEDIn this Dental Office/Practice/Facility:D. RESUSCITATION MASKS OR DEVICES Mouthpieces, resuscitation bags, pocket masks and/or ventilation bags are readily available foremergency situation and/or CPR training.Location of resuscitation device(s): ________________________ _______________________E. OTHER PROTECTIVE CLOTHING/DEVICES Additional protective wear is worn, as appropriate, for the task being performed. Situations whichwould require such protection (e.g., gloves, masks) are as follows:______________________ ______________________ _______________________F. DISPOSAL, STORAGE, CLEANING AND LAUNDERING Personal protective equipment (e.g., gloves, masks) is disposed of as follows:______________________ ______________________ _______________________(List appropriate containers for disposal) Reusable personal protective equipment (e.g., goggles, face shields, resuscitation masks or devices) arecleaned as follows: Gowns/lab coats are stored before laundering in appropriately labeled/color-coded containers andlaundered by: Gowns/lab coats are laundered at NO COST to employees. All repairs and replacements of personal protective equipment are made atNO COST to employees (e.g., gloves, masks).OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 18

HOUSEKEEPINGIn this Dental Office/Practice/Facility:A. GENERAL HOUSEKEEPINGThis dental office/practice facility is cleaned and decontaminated according to a regular schedule: Daily Other:(Please specify)B. CLINICAL AREA DECONTAMINATION All surfaces/equipment contaminated with blood or other potentially infectious materials aredecontaminated by utilizing the following EPA registered, tuberculocidal disinfectant(s):______________________ ______________________ _______________________(Name of disinfectant(s)) A spray/wipe/spray method of decontamination is used. Surfaces are left wet for ______ minutes(as prescribed by the manufacturer). All contaminated work surfaces are decontaminated after completion of patient treatment proceduresand immediately or as soon as feasible after any spill of blood or other potentially infectious materials,and also at the end of the work shift if the surface has become contaminated since the last cleaning. Protective covers are used to shield equipment or surfaces which, because of location or design, aredifficult to clean and disinfect adequately. All bins, pails, cans and similar receptacles are inspected and decontaminated on a regularlyscheduled basis.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 19

HOUSEKEEPING CONTINUEDC. IN-HOUSE LAUNDRY PROCEDURES Universal precautions are utilized in the handling of all contaminated laundry. No labelingor color-coding of individual pieces of contaminated laundry is required in the dental office(although appropriate labeling of the bags and/or containers that the contaminated laundryis stored in is recommended). Employees are educated to recognize the hazards associated with the handling of contaminated laundry. Employees handling laundry contaminated with blood or other potentially infectious materials occursas little as possible. Laundry not labeled is placed in appropriately labeled bags and/or containers.Circle one: Biohazard labeled OR Color-coded red bag When laundry is wet, it is stored in a leak proof container.Please note: If this facility ships contaminated laundry off-site to anotherfacility the scope of work contract with the launderer will be required toutilize the equivalent of universal precautions.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 20

REGULATED WASTEDEFINITION OF REGULATED WASTE:Liquid or semi-liquid blood or other potentially infectious materials• Contaminated items that would release blood or other potentially infectious materials in aliquid or semi-liquid state, if compressed• Items that are caked with dried blood or other potentially infectious materials and are capableof releasing these materials during handlingContaminated sharps• Pathological and microbiological wastes containing blood or other potentiallyinfectious materialsIn this Dental Office/Practice/Facility: Regulated waste is placed in containers which are closeable, constructed to contain all contentsand prevent leakage. Regulated waste is placed in appropriately identified containers:Circle one: Biohazard Labels OR Red Containers Regulated waste containers are closed prior to removal to prevent spillage or protrusionof contents during handling.REGULATED WASTE SERVICE:NameAddressPhone NumberOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 21

HEPATITIS B VACCINATION AND ANTIBODY TESTINGDirections: The spaces below are to be completed by the employer. ________________________ makes available the Hepatitis B vaccine series to all coveredemployees (identified in this Exposure Control Plan) who are at riskof occupational exposure, at no cost to them after training and within10 days of initial employment.Please note: Vaccination is encouraged unless (1) documentation exists thatthe employee has previously received the vaccine series, (2) antibody testingreveals that the employee has previously received the series or (3) medicalevaluation shows that vaccination is contraindicated. ________________________ ensures that one or two months following the Hepatitis B vaccinationseries all employees who are at risk of occupational exposure will betested for HBV surface antibody. ________________________ ensures that vaccination is performed by or under the supervisionof a licensed physician, or by or under the supervision of anotherlicensed health care professional.Name/address of licensed physician or licensed healthcare professional ________________________ has determined that all laboratory testing is conducted by anaccredited laboratory. Evidence of such accreditation is on file.Please note: It is the employer’s responsibility to assure that all laboratorytests be conducted by an accredited laboratory. Employer documentation(e.g., certification to verify this accreditation, such as CDC or College ofAmerican Pathologists or equivalent state agency, which participates in arecognized quality assurance program) is required. ________________________ ensures that employees who decline the Hepatitis B vaccination havesigned the OSHA required waiver indicating their refusal found onpage 24 of this Exposure Control Plan. ________________________ ensures that if an employee initially declines the Hepatitis Bvaccination, but at a later date, while still covered under theBloodborne Pathogens Standard, decides to accept thevaccination, the vaccination shall then be made available at no costto the employee.EMPLOYER PAGEATTENTIONOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 22

HEPATITIS B VACCINATION AND ANTIBODY TESTING CONTINUED ________________________ will file a statement (from the health care professional responsible forvaccination) which states whether the employee can or cannot bevaccinated for whatever reason and that, where appropriate, thevaccine has been administered. This is called the “HealthcareProfessional’s Written Opinion”. ________________________ will assure that the vaccination program is instituted and performed.Directions: The space below is to be filled in with the name of the person conducting the training. ________________________ provides training to employees on Hepatitis B vaccinations,addressing safety, benefits, efficacy, methods of administration andavailability.For more information on training requirements see pages 30-33 in this Exposure Control Plan.EMPLOYER PAGEATTENTIONOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 23

HEPATITIS B VACCINATION DECLINATION FORM MANDATORYFor use in this dental office/practice/facilityI understand that, due to my occupational exposure to blood or otherpotentially infectious materials, I may be at risk of acquiring Hepatitis Bvirus (HBV) infection. I have been given the opportunity to bevaccinated with Hepatitis B vaccine, at no charge to myself. However,I decline Hepatitis B vaccination at this time. I understand that bydeclining this vaccine, I continue to be at risk of acquiring Hepatitis B,a serious disease. If in the future I continue to have occupational exposureto blood or other potentially infectious materials and I want to bevaccinated with Hepatitis B vaccine, I can receive the vaccination seriesat no charge to me.Employee signatureDateOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 24

POST-EXPOSURE EVALUATION AND FOLLOW-UPFor use in this dental office/practice/facilityIn this Dental Office/Practice/Facility: When an employee receives an occupational exposure to blood or other potentially infectiousmaterial, first aid (e.g., clean the wound, flush the eyes or other mucous membrane) is administered assoon as feasible. All exposure incidents that occur are reported, investigated and documented.When the employee incurs an exposure, it is reported to:(Name of assigned staff person or employer)(Name of assigned staff person or employer) Following a report of an exposure incident, the exposed employee will immediately, or as soon aspossible (within 24 hours) be referred to the appropriate contracted health care provider for follow up.(Name, phone number, address of contracted health care provider)THE ABOVE STATED CONTRACTED HEALTH CARE PROVIDER will ensure that the exposedemployee will immediately, or as soon as possible, receive a confidential medical evaluation and followup including all of the following elements:Documentation of the routes of exposure and how the exposure incident occurred• Identification and documentation of the source individual, unless it can be established thatidentification is infeasible or prohibited by state or local law• The source individual’s blood shall be tested as soon as feasible and after consent is obtained inorder to determine Hepatitis B virus (HBV), Hepatitis C virus (HCV) and HumanImmunodeficiency Virus (HIV) infectivity• If the source individual is already known to be HBV, HCV and/or HIV positive, further testingneed not be performed• The health care provider must assure that the exposed employee is provided with the sourceindividual’s test results while complying with all laws protecting confidentiality of the source andexposed individualsOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 25

POST-EXPOSURE EVALUATION AND FOLLOW-UP CONTINUED• If source patient consent is not obtained:(Name, address of contracted health care provider/facility)shall establish that required consent cannot be obtained.Please note: Involuntary testing is limited by law and the conditions underwhich this can be performed are prescribed in Chapter 252.15 of theWisconsin Statutes. A copy of this regulation can be obtained by visiting theDivision of Public Health web site (http://dhs.wisconsin.gov) or contactingthe WDA — see appendix for contact information.• After obtaining consent, the exposed employee’s blood will be drawn and tested for HBV, HCVand HIV serological status.• If the employee does not give consent to test for baseline HIV during collection of blood, thebaseline blood sample may be preserved for at least 90 days. If the exposed employee elects tohave this baseline sample tested during this waiting period, the test should be performed as soonas feasible. Following a report of an exposure incident, the employer will ensure that the health careprovider responsible for the employee’s post-exposure follow-up is provided with thefollowing documentation:1) copy of the OSHA Bloodborne Pathogens Standard 29CFR 1910.10302) A copy of the Occupational Exposure Incident Report (see page 28 of this Exposure Control Plan)which includes the following:A written description of the employee’s job duties relevant to the exposure incidentRoute(s) of exposureCircumstances of the exposureIf possible, results of the source individual’s blood test• All medical records relevant to the appropriate treatment of the employee, includingvaccination status Following a report of an exposure incident, the employer will obtain and provide the employee with acopy of the evaluating Healthcare Professional’s Written Opinion within 15 days of the completion ofthe post-exposure evaluation and follow-up. This document includes the following:• Whether Hepatitis B vaccine is indicated in this case and if this person has received suchvaccinationstatement that the employee has been informed of the results of the post-exposure evaluation• A statement that the employee has been told about any medical conditions resulting fromexposure to blood or other potentially infectious materials which required evaluation ortreatment; all other findings or diagnoses shall not be included in the written reportPlease note: Timely reporting and follow-up of an exposure incident isessential so that chemical prophylaxis, if appropriate, can be administered inthe most effective manner (within two hours if source patient is HIV carrier,otherwise within 24 hours).OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 26

OCCUPATIONAL EXPOSURE INCIDENT REPORTA SIGNIFICANT EXPOSURE OCCURS:1) Following percutaneous exposure (i.e., penetration of dental health care worker’s skin by a needle, a scalpelblade or other sharp object contaminated with a patient’s blood or other potentially infectious materials).2) Following contact between dental health care worker’s oral or nasal mucous membrane, cornea ornon-intact skin and patient blood, saliva or other potentially infectious materials (i.e., a splash ofpatient blood, saliva or other potentially infectious materials into the mouth, nose or eye of the dentalhealth care worker or direct contact of patient blood saliva or other potentially infectious material withan abrasion, cut or other opening in the skin of the dental health care worker).EMPLOYEE INFORMATIONExposed employee’s name:Jane DoeFORMPhone:Position:(414) 123-4567Dental Hygienist3sDate of exposure:Date of HBV Vaccination:Date of Anti HBs test:Date of last tetanus toxoid Vaccination:INCIDENT DESCRIPTION: (What occurred and where did it happen? Describe theexposure and whether this is a percutaneous, mucous membrane or corneal exposureas described above. What body part was affected?)Needle stick, left thumb, while administering injectionSource patient antibody status (if known):SOURCE PATIENT INFORMATIONSource Patient HBsAg status: Positive x NegativeHIV antibody status: Positive x NegativeSource Patient HCV antibody status: Positive x NegativeI, ____________________________ Jane Doe understand the significance of my exposure, as described above,I have been offered medical evaluation and treatment for the exposure but have decided, for personalreasons, not to have any such treatment.Dr. John Doe(Employer’s signature)00/00/000000/00/000000/00/000000/00/0000Jane Doe(Employee’s signature)SAMPLEThis document is CONFIDENTIAL and must be maintained by the employer for the length of employment plus 30 years.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 27

OCCUPATIONAL EXPOSURE INCIDENT REPORTFor use in this dental office/practice/facilityA SIGNIFICANT EXPOSURE OCCURS:1) Following percutaneous exposure (i.e., penetration of dental health care worker’s skin by a needle, a scalpelblade or other sharp object contaminated with a patient’s blood or other potentially infectious materials).2) Following contact between dental health care worker’s oral or nasal mucous membrane, cornea ornon-intact skin and patient blood, saliva or other potentially infectious materials (i.e., a splash ofpatient blood, saliva or other potentially infectious materials into the mouth, nose or eye of the dentalhealth care worker or direct contact of patient blood saliva or other potentially infectious material withan abrasion, cut or other opening in the skin of the dental health care worker).EMPLOYEE INFORMATIONExposed employee’s name:Phone:Position:FORM3Date of exposure:Date of HBV Vaccination:Date of Anti HBs test:FORUSE INOFFICEDate of last tetanus toxoid Vaccination:INCIDENT DESCRIPTION: (What occurred and where did it happen? Describe theexposure and whether this is a percutaneous, mucous membrane or corneal exposureas described above. What body part was affected?)Source patient antibody status (if known):SOURCE PATIENT INFORMATIONSource Patient HBsAg status: Positive NegativeHIV antibody status: Positive NegativeSource Patient HCV antibody status: Positive NegativeI, ____________________________ understand the significance of my exposure, as described above,I have been offered medical evaluation and treatment for the exposure but have decided, for personalreasons, not to have any such treatment.(Employer’s signature)(Employee’s signature)This document is CONFIDENTIAL and must be maintained by the employer for the length of employment plus 30 years.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 28

COMMUNICATION OF HAZARDS TO EMPLOYEES AND TRAININGIn this Dental Office/Practice/Facility:LABELS AND SIGNS(Name of assigned staff person) Will ensure that biohazard labels are affixed to containers of regulated waste, refrigerators andfreezers containing blood or other potentially infectious materials and other containers used tostore, transport or ship blood or other potentially infectious materials (e.g., extracted teeth, biopsymaterial).The universal biohazard symbol is used and this label must be fluorescent orange or orange red.Please note: Red bags or containers may be substituted for labels.However, regulated waste is handled in accordance with the rules andregulations of the agency (Wisconsin Department of Natural Resources)having jurisdiction over waste disposal regulations.EMPLOYER PAGEATTENTIONOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 29

INFORMATION AND TRAININGIn this Dental Office/Practice/Facility:(Employer’s Name) Will ensure that training is provided at the time of the initial assignment of tasks where occupationalexposure may occur and that it is repeated within 12 months of the previous training. The training willbe tailored to the education and language level of the employee and offered during the normal workhours.The training provided in this dental office/practice/facility is interactive and covers the following:copy of the OSHA standard and an explanation of its contents• A discussion of the epidemiology, symptoms and modes of transmission of blood bornepathogens, including HIV, HBV and HCV• An explanation of this office’s Bloodborne Pathogens Exposure Control Planand a how to obtain a copy• An explanation of methods to recognize tasks and other activities that may involve exposure toblood and other potentially infectious materials, including what constitutes an exposure incident• An explanation of the use and limitations of engineering controls, work practices and personalprotective equipment including specific training on engineered sharps usedAn explanation of the basis of selection of personal protective equipment• Information on the types, use, location, removal, handling, decontamination and disposal ofpersonal protective equipment• Information on the Hepatitis B vaccination, including information on its efficacy, safety,method of administration, the benefits of being vaccinated and that the vaccine will be offeredfree of charge• Information on the appropriate actions to take and persons to contact in an emergency involvingexposure to blood or other potentially infectious materials• An explanation of the procedures to follow if an exposure incident occurs, including the methodsof 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 toprovide for the employee following an exposure incident• Information on timely reporting of an exposure incident so that chemical prophylaxis, ifappropriate, can be effectively administered in a timely manner• An explanation of the signs, labels, and/or color-coding required by the standard and used in thisoffice/practice/facilityEMPLOYER PAGEATTENTIONOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 30

INFORMATION AND TRAINING CONTINUEDThis training will be provided by:Name/address of person conducting trainingThe person conducting the training is knowledgeable in the subject matter and the workplace.An opportunity is provided for interactive questions and answers with the person conducting thetraining session. Employees who have received training on bloodborne pathogens in the preceding twelve (12) monthsshall only receive training in provisions of the policy that were not covered — new regulation changesin ECP. Additional training will be provided to employees if and when there are any changes of tasks orprocedures affecting the employee’s occupational exposure — changes in employment. Additional training will be provided to employees if and when there are any changes as the result of theNeedlestick Safety and Prevention Act.The following information shall be documented in the training record(see page 33 in this exposure control plan):The date(s) of the training session(s)• An outline describing the materials presentedThe names and qualifications of persons conducting the training• The names and job titles of all persons attending the training sessionsReminder: Don’t forget to consistently document your training sessions, outlines, etc.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 31

OSHA BLOODBORNE PATHOGENS STANDARD TRAINING RECORDDr. Doe DentalName of Dental Office/Practice/Facility000 Apple StreetAnytown USA 12345Address00/00/0000 Dr. John Doe, Jane DoeDate of trainingName(s)attended several seminars, etc., trainerQualifications* of person conducting trainingFORMSIGNATUREName of persons attending this training session:POSITION/TITLE4sCindy R.Michael T.Jane D.Erik B.Connie S.Jessica F.Dental AssistantDental AssistantDental AssistantDental HygienistDental HygienistReceptionistSAMPLEThis training record must be maintained for three years from the date of the training session.*Qualifications include: degrees, training experience, courses given and attended etc.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 32FORUSE IN

OSHA BLOODBORNE PATHOGENS STANDARD TRAINING RECORDFor use in this dental office/practice/facilityName of Dental Office/Practice/FacilityAddressDate of trainingQualifications* of person conducting trainingName(s)FORMSIGNATUREName of persons attending this training session:POSITION/TITLE4FORUSE INOFFICEThis training record must be maintained for three years from the date of the training session.*Qualifications include: degrees, training experience, courses given and attended etc.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 33

RECORD KEEPINGIn this Dental Office/Practice/Facility:Name of assigned staff person or employerwill maintain the following records relevant to the OSHA Bloodborne Pathogens Standard29CRF 1910.1030:Occupational Exposure Incident Reports (see page 28)Hepatitis B Vaccine Declination Form (see page 24)• Employer’s First Report of Injury or Disease/DWD*/Workers’ Compensation formsrelevant to occupational exposures to blood or other potentially infectious materials• Health Care Provider’s Written Opinion regarding employee’s ability to receiveHepatitis B Vaccine• Training Records (see page 33)Medical records are kept(location)All medical records are strictly confidential and will be retained for the duration of employment plus 30 years.Training records are kept(location)OSHA Bloodborne Pathogen training record (see page 33) and all training recordswill be retained for three years from the date of training.*Wisconsin’s Department of Workforce DevelopmentOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 34

EVALUATION AND REVIEW OF EXPOSURE CONTROL PLANIn this Dental Office/Practice/Facility:Name of assigned staff person or employerWill ensure that this exposure control plan is reviewed and updated as necessary. The review will beaccomplished at least annually and more often if and when changes in employment responsibilities or inthe use of engineering and/or work practice controls occur. Such changes will be documented in thisExposure Control Plan (examples include a change in laundry service or contracted health care facilityprovider).REVIEWSREVIEW DATES ASSIGNED STAFF PERSON NAME/POSITION ASSIGNED STAFF PERSON SIGNATUREOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDA 35

APPENDIXEMPLOYER REFERENCE PAGESOCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)MissionThe mission of the Occupational Safety and Health Administration (OSHA) is to save lives, preventinjuries and protect the health of America’s workers. To accomplish this, federal and state governmentsmust work in partnership with the more than 100 million working men and women and their six anda half million employers who are covered by the Occupational Safety and Health Act of 1970.Employer LiabilityThe employer is ultimately responsible for any and all violations of the mandates set forth by OSHA. Itis imperative that the employer takes an active role in overseeing and ensuring that the appropriate officeprocedures, materials, etc., are in place for OSHA compliance purposes. It is also in the best interest of theemployer to be aware of any new regulations and corresponding compliance deadlines.Employer (Dentist) Liability Article:Written By Dr. Elise SampsonMany dental office employers designate a staff person or persons to be responsible for administering theOSHA regulations. While this is perfectly appropriate, please remember that it is the dentist/employerwho is ultimately responsible for assuring full compliance with these regulations. Here are a fewsuggestions and explanations to help the dentist/employer comply with the requirements of the OSHABloodborne Pathogens Standard.In order to be in compliance the employer must:1.) Perform an EXPOSURE DETERMINATION.Decide which of your employees are eligible for the benefits provided by the BloodbornePathogens Standard. In a dental office, this will include any person who comes in contact withblood, saliva* and/or other potentially infectious material at any time during the course of theirwork. This includes, but is not limited to, dentists, dental hygienists, dental assistants, labtechnicians and equipment maintenance personnel. No distinction is made between full-time andpart-time staff. A person who performs exposure prone procedures only occasionally is still eligiblefor the benefits of the Standard. For instructions on how to complete an Exposure Determinationsee pages 4-6 of the WDA Exposure Control Plan.2.) Make available to employees a COMPREHENSIVE EXPOSURE CONTROL PLAN.An Exposure Control Plan must document the methods used to comply with all BloodbornePathogens Standard regulations. It is important that the written statements in the ExposureControl Plan you use describe exactly how, and by whom, the procedures are carried out in thedental office.* Saliva — whenever oral tissues are manipulated during a dental procedure bleeding is likely to occur. Becauseof this, saliva in dentistry must be considered a potentially infectious material and therefore capable oftransmitting bloodborne diseases.(continued on a2)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa1

APPENDIX3.) Provide TRAINING and ANNUAL RETRAINING for all employees listed in the exposuredetermination.The major purpose of the training is to help employees understand the potential risk to themof exposure to blood, saliva and other potentially infectious materials, the consequences of thoserisks and how to work safely to avoid/reduce them. In addition, the training must informemployees of the safeguards and procedures which have been established in your workplace tohelp them if they are accidentally exposed to blood or other potentially infectious material.The person who performs the training must be familiar with the work environment of the peoplebeing trained and be able to answer their questions.New employees must be trained before beginning work in an exposure prone environment evenif they are wearing protective equipment.If an employee’s work exposure risk changes as a result of being moved to a different job withinthe dental office, additional training must be provided at that time.For additional information concerning training requirements and documentation see pages 30-33of the WDA–OSHA Exposure Control Plan.4.) Purchase PERSONAL PROTECTIVE EQUIPMENT for use by your employees including, butnot limited to gloves, masks, eye protection and a gown or lab coat. The personal protectiveequipment must be available to employees at no charge.5.) Purchase ENGINEERING CONTROLS including, but not limited to, sharps containers, rubberdams, high volume suction and so on.6.) Make HEPATITIS B VACCINE AND POST VACCINATION TESTING easily available at nocharge whatsoever to employees.It is the employer’s ultimate responsibility to make sure that personal protective equipment andengineering controls are not only available and easily accessible, but also that the equipment is usedappropriately and consistently as documented in the Exposure Control Plan. (See page 16)It is the employer’s ultimate responsibility to see to it that employees use safe work practices asdescribed in dental office Exposure Control Plan especially when handling and recapping syringeneedles and other sharp disposable and reusable instruments and equipment.Employees must be offered Hepatitis B Vaccine after receiving training, which explains the risks ofHepatitis B infection and the benefits, limitations and possible side effects of vaccination. Employees whorefuse the vaccine must read and sign the Vaccination Declination Form, which can be found on page 24of the WDA-OSHA Exposure Control Plan. Employees who are identified in your ExposureDetermination, may change their minds at any time and request to be vaccinated at no charge.(continued on a3)OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa2

APPENDIXThe Hepatitis B vaccine does not protect everyone who is vaccinated. To find out if vaccination hasproduced protective antibody in each person vaccinated the employer must offer, and pay for, Hepatitis Bantibody testing. This is done approximately four to six weeks after completion of the series of threevaccine injections. Follow up boosters or revaccination for individuals who are antibody negative isdetermined by the health care provider who performs the testing. The employer is not responsible forrevaccination costs. However you may consider it appropriate to do so.The health care provider who performs this vaccination should supply you with a written document foreach employee stating whether that person could or could not be vaccinated. You will keep this statementon file. If and when an employee receives an occupational exposure, they must take this document withthem to the health care provider who performs post-exposure testing and follow-up.7.) Develop a well-organized POST-EXPOSURE POLICY for your workplace.An exposure incident can be a distressing experience for the person(s) involved. It is in the bestinterest of the entire dental office to be well prepared before an incident occurs. The followingsuggestions should help reduce any problems associated with such an incident:Make sure all employees are trained to understand what constitutes an occupational exposure.• See to it that all employees know who to report to (in the office) when an exposure incidentoccurs.• Whenever possible, name an alternate person to handle incidents when the designated person isunavailable.• See to it that each incident is documented properly by completing the incident report which canbe found on page 28 of the WDA OSHA Exposure Control Plan.• Designate an informed/experienced person to explain the situation and follow-up to the sourcepatient, if known. (Obtaining cooperation of the source patient is very important to the finaloutcome of this process.)• Develop a professional relationship with a local hospital and/or occupational health clinic, whichhas experience in dealing with health care worker injuries. Request a contact phone number tocall when an exposure incident occurs to inform the health care provider that you are referringan employee and a source patient to them. This will save time, reduce confusion and assure thatthe necessary record keeping is properly handled.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa3

APPENDIXWDA JOURNAL ARTICLE — MAY 2000Employer Information/Rights at the Time of an OSHA Inspection(Further information is found in the Frequently Asked Questions—a5)a.) All OSHA related complaint(s) or proceedings are confidential (will not be published).b.) OSHA does not have to tell the dental office about the person who issued the complaint.OSHA will know who triggered the investigation, but they are not obligated to share thatinformation with the dental office.c.) You (the employer) have the right to be present at the inspection of your practice.d.) If your patient load is being compromised, you can ask the inspector to return at a moreconvenient time.e.) Under the fourth amendment, you have the right to demand a warrant from the inspectorprior to the inspection of your office.f.) If you demand a warrant, the inspection should be limited to what is stated in the warrant.The warrant should also reflect what is stated in the complaint, if you believe the complaint istoo broad or if the inspector tries to go beyond what is stated in the warrant, you have theoption of calling off the inspection.g.) OSHA inspectors usually conduct an exit interview to communicate (with the employer)which violations he or she believes exist and what the maximum potential fines are for theseviolations.h.) You have the right to contest citations within a 15-day working period.i.) You can request an informal conference with an OSHA area director to reach a settlement.j.) When receiving a citation and notification of penalty, you must post the citation or a copy ofit at or near the place where each violation occurred to make employees aware of the hazardsto which they may be exposed.k.) Citations must remain posted for three working days or until the violation is corrected,whichever is longer (holidays, weekends — do not count).l.) Citation posting is required even if you wish to contest the violations.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa4

APPENDIXEMPLOYER FREQUENTLY ASKED QUESTIONSOSHAOSHAOSHAADAADAADAADAYES — all employers need to post the federal and state OSHA posters to provide theiremployees with information on their safety and health rights. You may order a printed copyfrom OSHA Publications at 1-800-321-OSHA or download a copy from the OSHA Web siteat: http://www.osha.gov/ — Also please see appendix pages a9-a10 for state and federal posterrequirements.Do I need to put up an OSHA poster in my workplace? Where can I get a copy?In fiscal year 2000, OSHA conducted 36,350 inspections of a wide variety of employer facilitiesand worksites. The 26 individual states running their own OSHA programs conducted anadditional 54,510 inspections.How many inspections does OSHA conduct each year?Employers have the right to contest OSHA citations and/or penalties before the IndependentOccupational Safety and Health Review Commission. Notices of contest must be filed within15 business days following the issuance of the citations.What if I disagree with the inspection findings?What happens if an employee files a complaint with OSHA?If OSHA believes the complaint provides probable cause that a violation exists, there will likelybe an inspection; this is true for current employees as well as former employees.If OSHA does not believe the complaint provides probable cause they may send you a letter,which will state the substance of the complaint. You will be asked to respond in writing to thealleged violations and to describe the steps you will take to correct them. If OSHA is notsatisfied with your plan (or this plan indicates another violation exists) an in-person OSHAinspection might then take place.Will I have advanced warning of an inspection?Probably not. You have no right to advanced warning.How do I know if someone who comes to my door is an inspector?Inspectors carry a badge and card that identify them as OSHA inspectors.Persons who falsely represent themselves as federal officers are guilty of a crime.Can OSHA interview all of my employees?Probably not. But, OSHA has the right to interview a reasonable sampling of your employees.Of course, OSHA will dictate what a “reasonable sampling” is, based upon the factsand circumstances of the case. If you feel the inspector is going too far, you shouldconsider objecting.OSHA Information cited from OSHA ADA Information cited from the ADAOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa5

APPENDIXUSEFUL DEFINITIONSBloodborne Pathogens: pathogenic microorganisms that are present in human blood and can causedisease in humans. These pathogens include, but are not limited to, Hepatitis B Virus (HBV), Hepatitis CVirus (HCV), and Human Immunodeficiency Virus (HIV).Contaminated: the presence or the reasonably anticipated presence of blood or other potentially infectiousmaterials on an item or surface (including saliva in dentistry).Decontamination: the use of physical or chemical means to remove, inactivate or destroy bloodbornepathogens on a surface or item to the point where they are no longer capable of transmitting infectiousparticles and the surface or item is rendered safe for handling, use or disposal.Engineering Controls: mechanisms that isolate or remove the bloodborne pathogens hazard from theworkplace (e.g. sharps disposal containers, self sheathing needles).Exposure Determination: means employers must identify all job classifications in which the duties includedirect contact with patient mucous membranes, and/or contaminated instruments, equipment, appliances,waste, laundry, etc. Personnel performing these jobs could be exposed to blood or other potentiallyinfectious materials and are entitled to the full protection of the OSHA Bloodborne Pathogen Standard(e.g. dentist, dental assistant, hygienist, lab technician, equipment maintenance staff).Employees whose job classification does not normally include direct contact with blood or otherpotentially infectious materials, but who may sometimes be called on to perform exposure-prone task,must be identified and a complete list of potentially exposure prone tasks they could be asked to performmust be documented (e.g. secretary, business manager, receptionist who is asked to clean up operatory,sterilized instruments, handle contaminated equipment when dental assistant is absent).Exposure Incident: means specific eye, mouth, other mucous membrane, non-intact skin or parenteralcontact with blood or other potentially infectious materials that result from the performance of anemployee’s duties.General Duty Clause: all employers must furnish employees a place of employment free from recognizedhazards that are causing, or are likely to cause, death or serious harm.Needleless Systems: describes devices that do not use needles to collect bodily fluids or withdraw bodyfluids (after initial vascular access is established) in order to administer medication or fluids.Occupational Exposure: reasonably anticipated skin, eye, mucous membrane or parenteral contact withblood or other potentially infectious materials that result from performance of an employee’s duties.Sharps with Engineered Sharps Injury Protection: describes a non-needle sharp or a needle device usedfor withdrawing body fluids, accessing a vein or artery or administering medication or other fluids with abuilt in safety feature or mechanism that effectively reduces the risk of an exposure incident.OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa6

APPENDIXWEB SITES FOR REFERENCE DOCUMENTS/OTHER HELPFUL CONTACTSMember dentists may contact the WDA Madison Office at 1-888-538-8932to have copies of the documents listed below mailed.Occupational Safety and Health AdministrationIncludes regulations and forms for Blood Borne Pathogens Standard 29 CFR 1910.1030www.osha.govCDC Guidelines for Infection Control in Dentistrywww.cdc.govWisconsin Statute 252.15www.legis.state.wi.us/statutes/Stat0252.pdfWisconsin Department of Natural Resources — Guidelines for Infectious Waste Disposalwww.dnr.state.wi.usInfectious Waste Disposal; Recycling — WDA Guidance for Dentistswww.wda.orgNeedlestick Safety and Prevention Regulationwww.osha.govADA & OSHA Alliancewww.ada.orgWDA — OSHA Compliance Manual can be downloaded!Please see page a13 for more on WDA’s Web site resourceswww.wda.orgOTHER HELPFUL SOURCES QUESTION TYPE CONTACT INFORMATIONWisconsin Division of Public Health Safety & Public Health 1-608-266-1251Wisconsin Department of Natural Resources Disposal/Recycling 1-608-267-3548Centers for Disease Control & Prevention Infection Control 1-770-488-6054Wisconsin Dental Association Dental Specific 1-888-538-8932American Dental Association Dental Specific 1-800-621-8099Marquette University School of Dentistry Dental Specific 1-414-288-6928OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa7

APPENDIXREMINDER ON COMPLIANCE WITHOSHA NEEDLE SAFETY AMENDMENTSIn the fall of 2000, President Bill Clinton signed into law the Needlestick Safety Act, P.L. 106-430. The Actamends the Occupational Safety and Health Administration’s (OSHA) bloodborne pathogens standard to:1.) Document annually in the employer’s Exposure Control Plan, consideration and implementationof appropriate commercially available and effective engineering controls (including devices withengineered sharps injury protection or needleless systems) to eliminate or minimize exposure.2.) Solicit (from non-managerial employees who are potentially exposed to sharps injuries) input inthe identification, evaluation and selection of effective engineering controls, and document thesolicitation in the employer’s Exposure Control Plans.3.) Maintain the OSHA Form 200 log (only applies to employers with 10 or more employees) to keep arecord of percutaneous injuries from contaminated sharps.4.) Staff meetings/discussions are required to provide the opportunity for non-managerial staffto evaluate current in-office needle-safe devices, as well as recommend other needle-safe deviceoptions to the employer.This amendment to OSHA simply requires dental offices to review the availability of engineeringcontrols and consider their purchase and use in the dental office. It does NOT require dentists to usethe new safety needles and needleless devices if they are not considered safe for dental purposes.Regardless of the final decision on use, dental offices should regularly document their efforts to identify,evaluate and select engineering controls (safer needles) in their Exposure Control Plans. The updated rulesbecame effective on April 18, 2001.The following information is current as of July 2008 and is available at www.osha.gov:OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa8

APPENDIXOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa9

APPENDIXSTATE AND FEDERAL POSTER REQUIREMENT FOR EMPLOYERSErika Brown, Dental Practice and Government Relations Associate, ebrown@wda.orgThe purpose of this article is to keep dental employers informed of the poster requirements mandated bystate and federal law. It is important that dental employers comply with information postingrequirements. To ensure staff access to the information, posters should be displayed in “plain viewingsight”.The following is a comprehensive list of state and federal posters required for either all employers(regardless of staff size) or for employers with 50 or fewer employees. For the purposes of this article, it isassumed that dental employers in Wisconsin generally maintain staffs much smaller than the referencedminimum of 50 employees. Therefore, any poster requirements that apply only to employers with 50 ormore employees have been omitted from this listing.For further information on posting requirements, please contact Government Services Director MaraBrooks (mbrooks@wda.org) or Dental Practice and Government Relations Associate Erika Brown(ebrown@wda.org) in the WDA Madison office at 888-538-8932.STATE REQUIREMENTSInternet: http://www.dwd.state.wi.us/dwd/posters.htmNOTE: Posters can be accessed and printed directly through the state Web site. Posters printed directlyfrom the state Web site meet posting requirements.Phone: For document sales call 800-DOC-sale or 608-266-6861ALL EMPLOYERS (Including those with 50 or fewer employees)POSTER REQUIRED CODE LAST REVISED EXPLANATIONFair Employment LawEnglishERD-4531-PSpanishERD-4531-S-PHmongERD-4531-H-P06/2006All employers are requiredto display this posterRetaliation Protection for HealthCare WorkersERD-12210-P06/2006All employers who arehealth care providers orwho own or manage ahealth care facilityUnemployment Benefits, Notice toEmployees About ClaimingEnglishUCB-7-PSpanishUCB-7S-PHmongUCB-7-H12/2007All employers who aresubject to Wisconsin’sUnemploymentCompensation Law arerequired to post the posterOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa10

APPENDIXONLY FOR EMPLOYERS HIRING MINORSPOSTER REQUIRED CODE LAST REVISED EXPLANATIONHours and Days of Work Minors MayWork in WisconsinEnglishERD-9212-PVietnameseERD-9212-Vietnamese-PSpanishERD-9212-S-PChineseERD-9212-Chinese-P06/2006 All employers, exceptagriculture and domesticservice, who hire minorsare required to display theposterOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa11

APPENDIXFEDERAL REQUIREMENTSInternet: http://www.dol.gov/osbp/sbrefa/poster/main.htmPhone: Each agency has a separate phone number; please see below.ALL EMPLOYERS (Including those with 50 or fewer employees)POSTER REQUIRED CODE EXPLANATIONEqual Opportunity is the Law, AgeDiscrimination, Americans WithDisabilities ActNo poster code listedContact: U.S. Equal EmploymentOpportunity Commission (EEOC)800-669-4000All employers covered by lawFederal Minimum Wage - YourRights Under the Fair LaborStandards LawWH-1088Contact:U.S. Labor Dept. Wage and Hour Div.Madison608-441-5221Milwaukee414-297-3585All employers covered by lawJob Safety & Health ProtectionOSHA-3165-EnglishOSHA-3167-SpanishContact:U.S. Dept. of Labor/ OSHAMilwaukee414-297-3315Appleton920-734-4521Madison608-441-5388All private employersOccupational Injuries and IllnessSummaryOSHA-300Contact:U.S. Dept. of Labor/ OSHAMilwaukee414-297-3315Appleton920-734-4521Madison608-441-5388All employers covered byOccupational Safety and HealthAct of 1970 and all publicemployers covered under COMM 32;this poster must be postedFebruary 1 - April 30thRequired of all employers with10 or more employeesYour Rights Under USERRAThe Uniformed ServicesEmployment and Reemployment ActNo poster code listedU.S. Dept of Labor866-487-2365The Veterans Benefits ImprovementAct, enacted by Congress inDecember 2004, mandates thatemployers provide notice to allpersons entitled to rights andbenefits under USERRAOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa12

OSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa13

MEMBERSHIP COUNTSTRIPARTIE MEMBERSHIP SUMMARY OF SERVICESADAFederal NewsLegislative RepresentationPractice ResourcesWDAState NewsLegislative RepresentationPractice ResourcesLocal ComponentsMEMBER RESOURCESWDA Web SiteOnline Job Board/ClassifiedsPublications/E-NewslettersLEGISLATIVE REPRESENTATIONMonitoring of Regulation and LegislationDENTAL BENEFITSContract AnalysisAssistance with Dental ClaimsCOMPONENT MEETINGSProfessional NetworkingLocal and State NewsCE PresentationsContact with Elected OfficialsCOMMITTEESGrassroots ActivismLeadership DevelopmentPROFESSIONAL ASSISTANCEDentists Concerned for DentistsPeer ReviewVARIOUS DENTAL COMMITTEESOpportunities for InvolvementLeadership DevelopmentNetworkingINSURANCE PRODUCTSLife, Disability, Long Term CareProfessional LiabilityHealth InsuranceAuto/HomeownersUmbrella PoliciesMedicare SupplementsTHE DENTAL RECORDElectronic FormsChartsEmergency DocumentationDental RecordsCONTINUING EDUCATIONAnnual Session—Jewel of the Great LakesCE Tracking System (Folder)PUBLIC AWARENESSMedia Campaign & RelationsCommunity Outreach ProgramsPatient Education InformationADA TOLL-FREE NUMBERADA Web SitePublicationsAnnual SessionFEDERAL LEGISLATIVE REPRESENTATIONRegulatory MonitoringDental BenefitsMULTIPLE COUNCILSOpportunities for ParticipationLeadershipState RepresentationPRODUCTS AND SERVICESADA Member AdvantagePatient FinancingWebMDOSHA EXPOSURE CONTROL PLAN…a member benefit from the WDAa14