Re: At The Same Time, Needles Are Responsible For An Alarming Number Of Medical Injuries

0 views

Skip to first unread message

Message has been deleted

Edelira Longinotti

unread,

Jul 15, 2024, 9:13:25 PM7/15/24

to nautriginblon

OSHA's final rule for Occupational Exposure to Bloodborne Pathogens [29 CFR 1910.1030(f)] requires the dental employer to make immediately available confidential medical evaluation and follow-up to an employee reporting an exposure incident. An exposure incident is any eye, mouth, mucous membrane, non-intact skin, or other parenteral contact with blood or other potentially infectious material (OPIM). (For example, a puncture from a contaminated sharp such as an injection needle or a cut from a scalpel blade or suture needle.) Saliva in dental procedures is treated as OPIM.

The dental employer must refer the exposed employee to a licensed health care professional. This means a person who is licensed under the laws of the state where he/she practices to independently provide the post-exposure evaluation and follow-up services required by the standard. The health care professional will counsel the individual about what happened and how to prevent further spread of any potential infection. He or she will prescribe appropriate follow-up in accordance with current U.S. Public Health Service recommendations. The licensed health care professional also will evaluate any reported illness to determine if the symptoms may be related to Human Immunodeficiency Virus (HIV) or Hepatitis B Virus (HBV) infection.

At The Same Time, Needles Are Responsible For An Alarming Number Of Medical Injuries

Download https://lpoms.com/2yLVCY

Note: The standard is designed to prevent occupational exposure to blood or OPIM. If the required controls are in place and the standard is correctly implemented, then exposure incidents will be relatively uncommon events.

Note: The bloodborne pathogens standard is a performance oriented standard. As such, it requires that medical evaluation and follow-up be provided in accordance with the U.S. Public Health Service recommendations, but does not cite specific recommendations. OSHA intentionally drafted the standard in this fashion to ensure that the most current recommendations would be followed.

Note: In the past, larger dental practices (those with 11 or more employees) have been required by a separate OSHA record keeping rule (29 CFR 1904) to record occupational illnesses or injuries and prepare an annual log of injuries and illnesses.

There is one, rare exception to this exemption. OSHA or the Bureau of Labor Statistics may require individual offices to maintain injury and illness records and logs for a year as part of their efforts to gather national injury and illness data. These offices would also have to report their data to the requesting agency. (OSHA Form 300 can be downloaded at )

*Some states operate their own OSHA programs under the authority of a State Plan approved by OSHA. States operating under OSHA-approved plans must have record keeping rules that are substantially identical to the federal requirements. However, they may adopt more stringent requirements. This might include eliminating the exemption for dental offices and other low risk workplaces. Dentists who practice in State Plan states should contact their constituent societies or their state OSHAs for more information about the record keeping requirements in their states.

Note: For those jurisdictions that do not require consent of the patient, the source patient's blood, if available, must be tested. The term "if available" applies to blood samples that have already been drawn from the source patient. OSHA does not require redrawing of blood for HBV and HIV testing without consent of the source patient.

In addition, for HIV, the 1996 CDC guidelines state that "chemoprophylaxis should be recommended to exposed workers after occupational exposures associated with the highest risk of HIV transmission. For exposures with a lower, but non-negligible risk, postexposure prophylaxis should be offered, balancing the lower risk against the use of drugs having uncertain efficacy and toxicity. For exposures with negligible risk, postexposure prophylaxis is not justified."

Note: This requirement should not be construed to mean that the dental employer is responsible for the cost of treatment of disease, which is beyond the scope of the standard's follow-up requirements.

The dental employer must provide a copy of the evaluating health care professional's written opinion to the exposed employee within 15 days of the completion of the evaluation. The original document should be placed in the employee's confidential medical record.

Under the standard, dental employers may have to rely on the health care professional to carry out certain OSHA obligations, such as maintaining employee medical records in a confidential manner, retaining the records for the duration of employment plus 30 years and providing appropriate post-exposure evaluation and follow-up services. The dental employer has an obligation to ensure compliance with the standard. However, he or she will not generally be held liable for violations resulting from the health care professional's actions if the dental employer has acted in good faith to contract with a responsible entity and has no reason to foresee that the contractor will not fulfill its obligations.

Prepared by the American Dental Association in cooperation with the Occupational Safety and Health Administration (December 1997). This document is not considered a substitute for any provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by OSHA.

Yes, it is the dental employer, rather than the employee, who is entitled to select a health care professional to provide the hepatitis B vaccination and post-exposure evaluation and follow-up services required under the standard. Dental employers would be wise to select a health care professional who is familiar with the standard and the recommended post-exposure evaluation and follow-up protocol. The U.S. Public Health Service recommends that when possible, the medical evaluation and follow-up should be implemented in consultation with persons having expertise in antiretroviral therapy and HIV transmission. On this basis, the dental employer should identify, and have on record, a health care professional with appropriate expertise, or a healthcare professional who consults with a person having such expertise.

Employer Obligation Related to CDC Recommendations
Since the standard incorporates by reference the CDC recommendations for post-exposure prophylaxis, what is the dental employer's obligations when the CDC guidelines are not clear or when the health care professional recommends treatment beyond what is contained in the CDC guidelines?

Under the standard, it is the dental employer's responsibility, following an exposure incident, to make immediately available to the exposed employee post-exposure prophylaxis, when medically indicated. The standard requires that post-exposure prophylaxis be provided in accordance with the recommendations of the U.S. Public Health Service, but it does not cite specific recommendations.

OSHA intentionally drafted the standard in this fashion to ensure that the most current recommendations would be followed. Because post-exposure testing and prophylaxis are rapidly changing and developing fields, it must be provided according to recommendations of the U.S. Public Health Service current at the time post-exposure testing and prophylaxis take place.

Currently, for employees who have not received the HBV vaccine series, HBV vaccine (and in some circumstances hepatitis B immune globulin) is to be offered as soon as possible after the exposure incident, but no more than seven days after the incident.

With regard to HIV disease, CDC guidelines for post-exposure antiretroviral drug therapy are constantly evolving. The HCP providing post-exposure evaluation and follow-up must ensure that current CDC guidelines are followed. In order to assist the evaluating HCP in following CDC guidelines, the dental employer must ensure that the exposed employee receives immediate post-exposure evaluation (according to the CDC, preferably within 1-2 hours, but no longer than 24 hours) after the exposure incident.

Note: The recommendations of the U.S. Public Health Service provides guidelines for post-exposure chemoprophylaxis. However, the use of post-exposure chemoprophylaxis is a clinical decision which should be individualized for each employee incident.

CDC guidelines and recommendations are widely distributed and readily available to health care professionals either directly from the CDC or through professional associations. Direct subscriptions to the Morbidity and Mortality Weekly Report (MMWR) are available. Due to the ever-changing nature of the health care industry, professionals routinely seek to keep themselves abreast of new developments. Therefore, OSHA does not anticipate that either dental employers or evaluating health care professionals will have any difficulty in obtaining any future CDC guidelines or recommendations. (See References.)

Confidentiality
Why is the dental employer denied access to the HBV or HIV test result of the employee and the source patient? How can the dental employer obey state laws implementing CDC guidelines on the practice of infected health care workers if the dentist is not entitled to know the employee's test results following an exposure incident?

It is very important to maintain confidential medical records to ensure that employees report exposure incidents and participate in post-exposure evaluation and follow-up. The standard requires that medical records be kept confidential and not disclosed without the employee's consent, except as required by the standard or as may be required by law. For example, if a law requires the information to be released to a county or state health department, the standard does not prohibit its release.

In addition, the standard does not prohibit the dental employer from providing routine testing of all of his or her employees to determine HBV and HIV status. Such routine testing would enable dental employers to learn the HBV and HIV status of all their employees, not just those few who suffer an exposure incident. Dental employers should be aware, however, that Federal, state or local laws that prohibit discrimination against the disabled may make it illegal to conduct routine employee testing. No dental employer should implement such a program without first obtaining the advice of his or her own personal attorney.