Guidelines and New Stuff
GUIDANCE FOR DENTISTS FROM THE CDC:
In order to protect staff and preserve personal protective equipment and patient care supplies, as well as expand available hospital capacity during the COVID-19 pandemic, the Centers for Disease Control and Prevention (CDC) recommends that dental facilities postpone elective procedures, surgeries, and non-urgent dental visits, and prioritize urgent and emergency visits and procedures now and for the coming several weeks. This aligns with recommendations from the American Dental Associationexternal icon (ADA) and the American Dental Hygienists’ Associationexternal icon (ADHA) to postpone non-emergency and elective dental procedures, as well the Centers for Medicare and Medicaid Services (CMS)’s guidancepdf iconexternal icon that all non-essential dental exams and procedures be postponed until further notice.
Click here for the Interim Infection Prevention and Control Guidance for Dental Settings During the COVID-19 Response
Click here for general information for healthcare workers who are working with suspected/confirmed COVID-19 patients (from the CDC).
Click here for information about a risk guidance in your office (from the CDC).
Click here for information from the ADA for OSHA guidance for handling patients during the Coronavirus pandemic. We are generally classified as low or medium risk, because we do not work on known or suspected COVID-19 patients. If we performed aerosol producing procedures on known COVID-19 patients in a hospital setting, we would be considered high/extremely high risk. (This is very helpful information).
Other New Stuff and Alerts:
- We DO have to get amalgam separators. The EPA has now reinstated the rule that general dentists and those who deal with amalgam removal would have to get amalgam separators installed. New offices must comply immediately with this regulation; existing offices have until July 14, 2020 to be in compliance. Click here for the requirements: amalgam separator requirements
- Please note that if you do eventually install one, most offices will want to get the type that uses sedimentation tanks, not the kind that uses filters. I have spoken to many dentists who say the filters fill up rapidly and the cost for new filters and disposal is huge, so consider that when deciding which type of system to purchase. Here is an old article from JADA that is very helpful because it explains what factors you have to consider when choosing the type of system: amalgam separator comparison
- We do need to sterilize slow speed handpiece motors. There have been some studies that show that pathogens can get into slow speed motors and can be transferred to the nosecone/heads/prophy angles during use. As a result, we do need to sterilize them between patients. (Some slow speed handpieces, specifically some of the new cordless prophy handpieces, do not need to be sterilized. Check with the manufacturer for the correct sterilization instructions.) Here is an article on slow speed handpiece contamination JADA 2007. And here is a copy of the CDC Statement on slow speed handpiece reprocessing .
- Be very careful to read all proposed contracts before using Stericycle!! Check out this article from the ADA about how much the prices have increased each quarter and how many states have sued Stericycle because of various issues: Stericycle…read the fine print!
- Also, just as an FYI, the federal rules governing biohazardous waste disposal has NOT changed at this time…we are under the same rules we have been under for years. Stericycle has changed THEIR policies about what items can go into sharps containers; the regulations have not changed. There are plenty of other companies who do the same service, so always check around for price comparisons. (You can also Google “sharps container pickup Dallas” or “medical waste disposal Spokane” for a list of local companies. If you’re in Georgia I’ve got a great company, so check it out on my Products and Services page)
- IT’S A SCAM!!! The U.S. Occupational Safety and Health Administration has learned of some businesses receiving fraudulent emails from scammers posing as the Department of Labor. The email advises recipients to download a guide to avoid being fined. The email had the subject: “OSHA Regulations — Avoid being fined.” While the sender may appear to be OSHA, — firstname.lastname@example.org — it’s not an OSHA-generated email. OSHA advises business owners who have received a message fitting the description to delete the message immediately and not click on any links. OSHA has alerted the appropriate authorities to the activity. (From ADA.org)
- Y’all know I don’t endorse products, and I get no money from them for any endorsements, but this is really a great product y’all should check out. fiteBac actually kills pathogens on your hands for at least 4 hours and it keeps your skin in great shape. Check it out and see what you think! Click here to read more!
- Click here for information on the Prescription Drug Monitoring Program Website. This website allows you to check whether a patient has received a controlled substance from another health care provider, but there are VERY strict rules as to how the information can be used… if you’re not careful, you could unintentionally commit a felony, so please check out this information!
- For new OSHA and HIPAA manuals, call the ADA catalog people at (800) 947-4746 (make sure you provide your ADA number; the prices listed are much higher for non-members.) For OSHA, you want the “Regulatory Compliance Manual”, which includes the update service and a CD ROM that allows you to customize forms (item #S696B, member price $275). The HIPAA compliance kit has the privacy and security information in one manual, plus a 3 year update service, and the customizable CD ROM,plus a basic HIPAA training DVD which can be used for new employees and for review purposes. The item # is J598 and the price for members is $300. They also have a package that includes the OSHA and HIPAA manuals and all the stuff listed above for $575 (Item # K017… and yes, there is apparently no discount for buying them together, but you do get some training stuff).
- Here are the requirements for security paper in Georgia. So long as the security paper meets Centers for Medicare & Medicaid Services requirements, it is sufficient. The good news is that you can get this tamper proof security paper at office supply stores instead of having to order it at a ridiculous price from a specified vendor.
- Many states (including Georgia) have decided that dentists cannot participate in programs such as Groupon, Half-off Depot, etc. because it is considered “fee-splitting” and is unethical. Medicare and Medicaid have said that participation is not allowed because it’s an illegal kickback. Whatever. The point is that, before you sign up for these programs, check with your state board to make sure it’s allowed.
- Here’s the deal on pharmaceutical waste. Contrary to what some companies have said, most states allow anesthetic carpules to be disposed of in the regular trash (unless there is aspirated blood in the carpule, or the carpule is broken, and those go in the sharps container). Carpules containing a mixture of lidocaine and epinephrine are specifically exempted from being considered hazardous under the federal rules, and can generally be disposed of in the regular trash. As far as other types of pharmaceutical waste, there may be some types of medications that are considered hazardous and must be disposed of as hazardous waste, but that is not most of the medications we use. Also, with the exception of certain excessively toxic drugs, (such as certain chemo and radiation related drugs), empty vials can generally be disposed of in the regular trash. ALL of the southern states have specifically stated that carpules can be thrown in the regular trash.
- For a great lawyer in Georgia (and a nice guy) who deals with dentists and our issues (employment issues, board/licensing issues, etc.), call Stuart Oberman: Oberman Law
- Dental Models are considered to be private health information, according to the HIPAA folks. As a result, any identifying information must be removed and they must be destroyed before disposal. Ugh.
- The best way to handle this is to hand models to the patients and ask them to throw them away at their house. Patients are allowed to do whatever they want with their private health information, so there are no issues with this.
- Another (possible) option would be to have a patient sign an authorization that says that the models can be disposed of in the regular trash without being destroyed, so long as the names are removed. However, I wouldn’t dispose of a large amount of them in the trash; if someone reported that they saw a bunch of models in the trash to the HIPAA folks, it could open you to a lot of scrutiny. I would ask your personal attorney if this is a good idea and show him this sample hipaa authorization to throw away models so he can configure it to work for your office.
- For CDC’s 2003 Infection Control guidelines for Dentistry Click here
- For a copy of OSHA’s Bloodborne Pathogens Standard, click here
- OSHA requires annual training for all who are possibly exposed to potentially infectious materials as part of their job duties. The annual training must be taught by a knowledgeable instructor, must be interactive, and must include all of the topics listed. For topics that must be covered during training, click here.
- For a copy of the CDC’s 2016 Infection Control Guidelines Summary (summarizes and clarifies some of the 2003 standard): click here
- For a copy of OSHA’s Needlestick Safety and Prevention Act, click here
- The Hazard Communication Standard has been revised as of March of 2012, but will not be fully implemented until June 1, 2016. The good news is that there are few changes that specifically affect us. We’ll have a new standardized form for all MSDS (now called “Safety Data Sheets” [SDS]) forms, standard labels, and standard hazard symbols (a picture of a flame for flammable items, etc.). Here’s the link for the new standard: click here
- For quick ( and free) training on the new requirements and pictograms, go to the online training tab and click on the video. It’s only 6 minutes and you can print out a form to show you received the training.
- For quick and basic information about new SDS forms, new symbols/pictograms, and new labels, go to the following link: http://www.osha.gov/dsg/hazcom/ghsquickcards.html
- Since the new standard incorporates portions of the old standard, if you don’t already have a copy in your manual, I would print the old standard and then place a link for the new standard on your computer or list the web address in your notebook so it’s available if an employee wants to read it: click here for the old standard and place it in your notebook. Here is a link for a copy of the new standard: click here (If you want to list the web address, it is: https://www.osha.gov/FedReg_osha_pdf/FED20120326.pdf )
- Make sure you have a current Hazard Communication Plan: click here. Fill it out and place it in your notebook. Also print out the following publication and place it with the Hazard Communication Plan (a great summary from OSHA on the new pictograms/labels/SDS requirements): click here
- It’s important to do our part to minimize the amount of mercury released into the environment. Here are the “Best Management Practices for Amalgam Waste” from the ADA: click here
- We’re supposed to have a copy of this standard in our OSHA notebook that basically says that employees have access to exposure records and medical records. Print it out and put in your OSHA notebook: click here
- For information about Premedication guidelines for dentistry, here is a great article from the ADA: Antibiotic Prophylaxis Prior to Dental Procedures
Required Plans for Dental Offices:
- This model Hazard Communication Plan is taken directly from OSHA, includes the new Hazard Communication information, and it’s edited to apply only to dentistry. Fill it out and place it with your OSHA materials. There’s a PDF version if you want to print and fill it out: (click for PDF version). Or here’s a version in WORD if you’d like to alter it for your office and print it out: (click for MS WORD version). Also, print out this summary of labels/SDS forms/pictograms and place it with the Hazard Communication Plan: click here
- Model Exposure Control Plan for Dentistry ONLY: The Model Exposure Control Plan is intended to serve as an employer guide to the OSHA Bloodborne Pathogens standard. The standard requires a current exposure control plan. This model is taken from OSHA, but edited to apply only to dentistry. click here to view / print
- This is a Model Exposure Control Plan for any Patient Care Facility, not just dentistry: click here to view / print
- Most dental offices are at low risk for TB transmission. To determine your risk for TB exposure, we are supposed to do a TB Risk Assessment annually. Here are some blank forms, plus an entire program I filled out for you. Choose whichever one you want and place it in your notebook.
- Model TB Infection Control Plan and TB fact sheets. Since we generally are low-risk environments according to the CDC, we are not usually required to have a written TB infection control plan. However, some states ask for this as part of the infection control plan, so here’s a sample one for you to use as necessary, along with fact sheets on TB): click here to print
- Here is a filled out TB risk assessment, plus a written TB plan. Fill in your community’s correct TB numbers, make any other changes as needed, put it in your notebook, and update once a year (it’s in a Word format so you can make changes): TB risk assessment and program
- Some states require a needle safety plan to explain how a practice handles sharps. You can use this plan as a sample to design a program specific to your office: click here to print
Specific infection control recommendations:
- US Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis (2001) click here . **Please note that some portions of this guideline have been updated by later publications.
- For the latest recommendations from the CDC about HIV postexposure prophylaxis (“Updated US Public Health Service Guidelines for the Management of Occupational Exposure to HIV and Recommendations for Post-Exposure Prophylaxis 2013”): click here
- For the latest recommendations from the CDC about HBV in health care workers and PEP after a stick (2013), click here.
- For additional information about infection control in all healthcare facilities (2008), click here
- For information about health care workers who have Hepatitis B (2012), click here
- For Questions and Answers about Hepatitis B, the Hepatitis B vaccine, titer testing, and boosters, check out this information from the CDC. click here
- For the new TB standard for health care workers (2005), click here
- To help prevent the transmission of respiratory infections in the dental office, the CDC recommends that patients use proper “cough etiquette“: click here
- For new guidelines to prevent the flu among health care workers, go here: FLU prevention for health care guidelines 2015
- Immunization of Health Care Workers, click here
- For more than you ever wanted to know about hand hygiene in health care settings, here are the CDC’s 2002 recommendations: click here
- X-Ray Badge Information: X-ray badges are only required for pregnant employees, as a general rule, but check with your local board to make sure it’s not required by your state. x ray info
- The Georgia Department of Community Health also recognizes that dental health care workers rarely receive enough radiation to require the use of dosimetry badges.
- To check out the Georgia laws, there are two links.
- Check out the recommendations from the FDA and ADA regarding the frequency and types of dental x-rays for various classes of patients: click here for – “The use of dental radiographs” or click here for ADA/FDA radiation recommendations.
Specific Government References for Dentistry:
OSHA’s Safety and Health Topics for Dentistry page: click here
CDC’s Infection Control in Dental Settings page: click here
PEP Hotline (888) 448-4911. Click here for the website.
NIOSH Workplace Safety in Dentistry website: click here