Roles and Responsibilities of the CDC and OSHA
The CDC is not a regulatory agency. Its role is to issue specific recommendations based on sound scientific evidence on health-related matters. Although not law, the CDC Guidelines for Infection Control in Dental Health Care Settings are now the standard of care. OSHA is a regulatory agency. Its role is to issue specific regulations, also called standards, to protect the health of employees in the United States. Failure to comply with OSHA requirements can have serious consequences, including heavy fines.
OSHA Bloodborne Pathogens Standard
OSHA's Bloodborne Pathogens Standard (BBP) is the most important infection control law in dentistry. It is designed to protect employees against occupational exposure to bloodborne, disease-causing organisms, such as hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV). The BBP requires employers to protect their employees from exposure to blood and other potentially infectious material (OPIM) in the workplace and to provide proper care to the employee if an exposure should occur. The standard applies to any type of facility in which employees might be exposed to blood and other body fluids, including dental and medical offices, hospitals, funeral homes, emergency medical services, and nursing homes. OSHA requires that a copy of the BBP Standard be present in every dental office and clinic. A copy of the OSHA BBP Standard may be obtained by visiting http:/ /www.osha.gov/SLTC/bloodbornepathogens/index/html.
The term universal precautions is still referred to in the OSHA BBP Standard. Universal precautions is based on the concept that all human blood and certain body fluids (including saliva) are to be treated as if known to be infected with the bloodborne diseases hepatitis B, hepatitis C, or HIV infection. The rationale for this concept is that it is not possible to identify those individuals who are infectious, so universal precautions were to be used for all healthcare personnel and their patients. The CDC expanded the concept and changed the term to standard precautions. Standard precautions apply not just to contact with blood, but also to (1) all body fluids, secretions, and excretions (except sweat) regardless of whether they contain blood; (2) nonintact skin; and (3) mucous membranes. Saliva has always been considered a potentially infectious material in dental infection control; therefore there is no difference in clinical dental practices between universal precautions and standard precautions. Standard precautions apply to contact with: Blood All body fluids, secretions, and excretions except sweat, regardless of whether or not they contain blood Nonintact skin Mucous membranes
The BBP defines an occupational exposure as “any reasonably anticipated skin, eye, mucous membrane contact, or percutaneous injury with blood or any other potentially infectious materials.” Percutaneous (through the skin, such as needlesticks, cuts, and human bites) and permucosal (contact with mucous membranes, such as the eyes or mouth) exposures to blood, saliva, and other body fluids pose the greatest risk for transmission of HIV, HBV, and HCV. The BBP Standard requires the dentist and/or employer to provide training in infection control and safety issues to all personnel who may come in contact with blood, saliva, or contaminated instruments or surfaces. The employer must keep records of all training sessions. The record of each training session must include the date of the session, the name of the presenter, the topic, and the names of all employees who attended.
Hepatitis B Immunization
The BBP Standard requires the dentist and/or employer to offer the HBV vaccination series to all employees whose jobs include categories I and II tasks. The vaccine must be offered within 10 days of assignment to a category I or II job. To document compliance, the dentist/employer