By Leslie Canham, CDA, RDA
An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties. Parenteral means piercing mucous membranes or the skin barrier through such events as needlesticks, human bites, cuts, and abrasions.
When an exposure incident occurs, immediate action must be taken to expedite medical treatment for the exposed employee and to assure compliance with the OSHA Bloodborne Pathogen Standard.
The OSHA bloodborne pathogen standard requires dentists to establish a written Exposure Control Plan (ECP). The ECP is designed to help employees identify, minimize, and eliminate risks of exposure to potentially infectious materials in the workplace. In addition, the ECP must contain information for the employee on what to do when an exposure incident occurs and who to contact for post-exposure evaluation and follow-up. Your ECP should be located in your office OSHA manual. If not, you can locate a Model Exposure Control Plan on the OSHA website.
The ECP requires some personalization. This means to establish policies and procedures based on your own workplace. Examples on personalizing your ECP include: instructions on what personal protective attire to wear, policies on handling contaminated items, and what steps to take in the event of an exposure incident.
Review your personalized exposure incident protocol at your next morning huddle or staff meeting. You can use the sample plan provided below and add details specific to your office. Specific details include: who to report to, what health-care provider will be used, where the first aid kit and eye wash station are located, where the required OSHA accident forms are, and how to obtain employee medical records, including vaccination status.
Sample exposure incident plan
1. Provide immediate care to the exposure site.
- Wash wounds and skin with soap and water.
- Flush mucous membranes with water.
- DO NOT USE instrument involved on patient!
- Employee must report incident immediately to supervisor/employer
2. Determine risk associated with exposure by ...
- Type of fluid (e.g., blood, visibly bloody fluid, or other potentially infectious fluid or tissue).
- Type of exposure (e.g., percutaneous injury, mucous membranes or non-intact skin exposure, or bites resulting in blood exposure).
3. Evaluate exposure source.
- Assess the risk of infection using available information.
- Source individuals (patients) must be asked if they know their HBV, HCV, HIV status. If not known, ask if they will consent to testing.
4. The exposed employee is referred as soon as possible * to a health-care provider who will follow the current recommendations of the U.S. Public Health Service Centers for Disease Control and Prevention recommendations for testing, medical examination, prophylaxis, and counseling procedures.
- Note “ASAP*” because certain interventions that may be indicated must be initiated promptly to be effective.
- The exposed employee may refuse any medical evaluation, testing, or follow-up recommendation. This refusal is documented.
5. The employer must send all of the following with the exposed employee to the health-care provider:
- A copy of the Bloodborne Pathogen Standard.
- A description of the exposed employee’s duties as they relate to the exposure incident. (Accidental Bodily Fluid Exposure Form)
- Documentation of the route(s) of exposure and circumstances under which exposure occurred. (Accidental Bodily Fluid Exposure Form)
- All medical records relevant to the appropriate treatment of the employee including HBV vaccination status records and source individual’s HBV/HCV/HIV status, if known.
6. The health-care provider (HCP) will:
- Evaluate the exposure incident.
- Arrange for testing of employee and source individual (if status is not already known).
- Notify the employee of results of all testing.
- Provide counseling and post-exposure prophylaxis.
- Evaluate reported illnesses.
- Send written opinion to employer limited to the following:
- Documentation that employee was informed of evaluation results and the need for further follow-up.
- Whether Hepatitis B vaccine is indicated and if vaccine was received.
Having a written exposure incident plan and reviewing it annually can help to expedite medical treatment for the exposed person. Remember time is of the essence because certain post-exposure medications are more effective if administered within hours of the incident rather than days. Be sure to locate a health-care provider near your office before you or anyone in your practice has an exposure incident.
You may request a complimentary copy of the sample exposure incident protocol (in Word document) to personalize a plan for your office by sending an email to Leslie@LeslieCanham.com.
Leslie Canham is a dental speaker and consultant specializing in infection control and OSHA compliance. She has more than 36 years of experience in dentistry. Canham is the founder of Leslie Canham Seminars, providing in-office training, mock inspections, consulting, and online seminars and webinars to help the dental team navigate state and federal regulations. Reach Canham at (888) 853-7543 or Leslie Canham.