NAVY RESERVE DENTAL CORPS

Bloodborne PathogensExposure Control Plan

POLICY

The Navy Reserve Dental Corps is committed to providing a safe work environment for military and non-military members and patients. Referencing OSHA standard 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens,” the following Exposure Control Plan (ECP) is provided to minimize risk of occupational exposure to bloodborne pathogens.

The ECP is the primary guide to ensure compliance with these standards, thereby protecting our member employees and patients. Together with the Hazard Communications Standards (Appendix D and E) and General Office Safety subcategories, the Bloodborne Pathogen Standards and ECP comprise the Navy Reserve Dental Corps Regulatory Compliance Manual. For the purposes of this manual, the employer is the Navy Reserve Dental Corps. Employees can be any military member or civilian working under the jurisdiction of the Reserve Dental Corps.

This ECP includes:

Determination of employee exposure. Implementation of various methods of exposure control, including:

Universal precautions Engineering and work practice controls Personal protective equipment Housekeeping

Hepatitis B vaccination. Post-exposure evaluation and follow-up. Communication of hazards to employees and training. Recordkeeping (to include a Sharps Injury Log). Procedures for evaluating and investigating exposure incidents. Annual review of safer medical devices and procedures.

Implementation methods for these elements of the standard are discussed in this ECP.

SCOPEThis Exposure Control Plan applies to all Navy Medical Treatment Facilities (MTF) and Dental Treatment Facilities (DTF) ashore and afloat and all employees, since all health care workers may experience occupational exposures to blood or other potentially infectious materials (OPIM). Additionally, all employees, including part-time, temporary, per diem, and contractors, must comply with the procedures and work practices outlined in this ECP.

Exposure Control Plan AdministrationExposure Control Plan Program Administrator: Infection Control Officer

The Infection Control Officer will maintain, review, and update the ECP at least annually, and whenever necessary to include new procedures.

SDEs will designate Unit Infection Control Officers to provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as

required by the standard. UICOs will also serve as designated Safety Monitors. All members should know who the Safety Monitor is at their respective facility.

SDEs will work with the Reserve Dental Corps to ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. This responsibility may be delegated to other competent personnel as deemed necessary at the discretion ICO and SDEs.

The ICO and SDEs will jointly be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. SDEs will administer and collect written documentation of training completion on the ascribed NAVRES 3500/2. SDEs will forward the 3500/2 to the ICO.

Exposure Control Plan (ECP) Availability & Training A digital copy of this ECP is available to all employees for download from the ICO. UICOs may also freely disseminate.

The Infection Control Officer in tandem with SDEs will facilitate training, documentation of training, and making the written ECP available to employees, and regulatory and accrediting agencies upon request.

All Dental Corps members will receive ECP training within ninety days of checking on board. All employees will also receive triennial refresher training, or earlier if deemed necessary by the Command.

The ICO is responsible for reviewing and updating the ECP annually, or more frequently as necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

Member Employee Exposure DeterminationCATEGORY I : EMPLOYEES EXPOSED TO BLOOD, SALIVA, BODY FLUIDS OR TISSUESThe following is a list of all job classifications in which all member employees will have occupational exposure to bloodborne pathogens:

Job Title Department/LocationHospital Corpsman (Dental Technician)

(All Clinical Areas)Dental Hygienist

Dentist

Prophy Technician

Radiology technician

Prosthodontic Laboratory technician

Bio-med repairmen

Sterilization Technician

CATEGORY II : EMPLOYEES WHO HAVE NO EXPOSURE TO BLOOD, SALIVA OR BODY FLUIDS OR TISSUES, BUT MAY BE REQUIRED TO PERFORM CATEGORY I TASKSThe following is a list of job classifications in which some member employees of the may have occupational exposure to bloodborne pathogens. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals:

Job Title/Department TaskNon-medical/dental billet desig that may occasionally assist with dental support Any necessary first aid

functions or housekeeping functions that may produce exposure

Non-medical/dental support staff that may occasionally assist with dental support

Facilities Maintenance/Housekeeping

CLASS III: EMPLOYEES INCLUDE CIVILIAN AND MILITARY PERSONNEL ASSIGNED TO ADMINISTRATION, FISCAL, OPERATIONAL MANAGEMENT AND SUPPLY DEPARTMENTS These employees have a low risk of exposure to bloodborne pathogens and OPIM.

Methods Of Implementation & Control

UNIVERSAL PRECAUTIONSAll member employees will receive training on the use of Universal Precautions (UP) and will be expected to use universal precautions at all times pursuant to their training.

Universal Precautions is a key prevention strategy and represents the overall strategy against bloodborne pathogens. Mandated by OSHA, universal precautions is an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens (Toxic and Hazardous Substances, 29 CFR 1910.1030(b)).

STANDARD PRECAUTIONSMost healthcare facilities have gone beyond Universal Precautions and choose to follow Standard Precautions. Standard Precautions incorporate the requirements of Universal Precautions and represent a higher level of precautions.

Standard Precautions and additional measures as noted below are considered to be industry-wide best practice.

The practice of Standard Precautions combines the major features of Universal Precautions (UP) and Body Substance Isolation (BSI) and is based on the principle that blood, body fluids, secretions, non-intact skin, mucous membranes, and excretions except sweat, may contain transmissible infectious agents.

PRECAUTIONS CATEGORIES:

• Tier I - Standard PrecautionsStandard Precautions are to be used on ALL patients, regardless of their diagnosis or presumed infectious status, when coming into contact (or risk of contact) with any of the following:

1) Blood.2) All body fluids, secretions and excretions.3) Non-intact skin.4) Mucous membranes.

• Tier II - Transmission Based Precautions - Isolation Categories:1) Contact Precautions.2) Airborne Precautions.3) Aerosol/Droplet Precautions.4) Combination of Isolation Precautions.

Engineering Controls And Work Practices 

POLICYThe policy of the Reserve Dental Corps is to select appropriate engineering controls and work practice controls designed to prevent or minimize exposure to bloodborne pathogens. Instruction of these controls and practices is expanded upon in the accompanying training, Principles of Sterilization.

ENGINEERING CONTROLS In regard to this ECP “Engineering Controls” refers to controls (e.g., sharps disposal containers, needle holders, safety syringes and sharps with engineered sharps injury protection) designed to isolate or remove the bloodborne pathogens hazard from the workplace.

Best workplace practices include: adhering to the “one handed scoop technique” to recap syringes, only the dental provider should recap needles, never leaving uncapped needles on the treatment tray, and never attempting to bend or break the needle.

The Reserve Dental Corps also encourages the practice of utilizing devices that are equipped with engineered sharps injury protection (ESIP) and needle safety best practices.

OSHA requires that all sharps including needles, needle devices and non-needle sharps be equipped with engineered sharps injury protection. This type of engineered protection means a physical attribute is built into a needle, needle device or non-needle sharp which effectively reduces the risk of exposure incidents by mechanisms such as barrier creation blunting, encapsulation, withdrawal or other effective mechanisms. In the dental office, most sharps do not come equipped from the manufacturer with engineered sharps injury protection devices built in. As these devices become available for dental utilization, these engineered sharps injury protection devices must be used when they are available for any type of sharp. OSHA’s exceptions for this regulation include: market availability- the engineered control is not available in the marketplace, patient safety- the engineered control is not required if a licensed healthcare professional directly involved in a patient’s care determines that use of the engineered control will jeopardize the patient’s safety or the success of the dental procedure involving the patient.

Engineered Sharp Injury Protection (ESIP) represents either:

• A physical attribute built into a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, which effectively reduces the risk of an exposure incident by a mechanism such as barrier creation, blunting, encapsulation, withdrawal, or other effective mechanisms; or

• A physical attribute built into any other type of needle device or into a non-needle sharp, which effectively reduces the risk of an exposure incident. We establish and maintain procedures for identifying and selecting appropriate and effective engineering controls that may include the following steps:

The specific Selected Engineering Controls and work practice controls the Reserve Dental Corps will utilize are listed below:

Sharps Container(s) Eye Wash Station(s) Hand washing Facilities Regulated Medical Waste Container(s) Needle holders Biohazard Labeled Container for Contaminated Laundry Amalgam Separators

Sharps disposal containers are inspected and maintained or replaced by UICO whenever necessary in order to prevent overfilling.Sharps containers are never to be more than 2/3 (two-thirds) full, or above the “fill line” designated on the container. Overfilling sharp containers may result in a sharp injury.

The Reserve Dental Corps identifies the need for changes in engineering controls and work practices through the following: Review of OSHA records/incidents, employee interviews, safety committee actions/decisions, etc.

The Reserve Dental Corps will evaluate new procedures and new products regularly by conducting Job Hazard Analyses, reviewing applicable regulatory standards (i.e. OSHA, CDC, etc.) and accreditation standards.Both Enlisted and Officers are involved in this process in the following manner:

Hazard Identification and Incident Reporting Job Hazard Analyses Safe Work Practices/Work Practice Controls

The NICO is the responsible party for ensuring that these recommendations are implemented and enforced at the SDE level.

Work Practice ControlsWork practice controls refer to safe behaviors or good work habits that will be used to reduce the chance of exposure to bloodborne pathogens. Work practice controls are safe behaviors which will minimize or eliminate puncture injuries, splashing, splattering, spraying, and the generation of droplets. Needle safety involves adhering to the “one handed scoop technique” to recap syringes, ensuring only the dental provider should recap needles, never leaving uncapped needles on the treatment tray, and never attempting to bend or break a needle.

HAND HYGIENEThe below material is quoted from Guideline for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings 2007:

Hand hygiene has been cited frequently as the single most important practice to reduce the transmission of infectious agents in healthcare settings and is an essential element of Standard Precautions.

The term “hand hygiene” includes both hand washing with either plain or antiseptic-containing soap and water, and use of alcohol-based products (gels, rinses, foams) that do not require the use of water. In the absence of visible soiling of hands, approved alcohol based products for hand disinfection are preferred over antimicrobial or plain soap and water because of their superior microbiocidal activity, reduced drying of the skin, and convenience.

Improved hand hygiene practices have been associated with a sustained decrease in the incidence of MRSA and VRE infections primarily in the ICU. The effectiveness of hand hygiene can be reduced by the type and length of fingernails. Individuals wearing artificial nails have been shown to harbor more pathogenic organisms, especially gram-negative bacilli and yeasts, on the nails and in the subungual area than those with native nails. In 2002, CDC/HICPAC recommended (Category IA) that artificial fingernails and extenders not be worn by healthcare personnel who have contact with high-risk patients (e.g., those in ICUs, ORs) due to the association with outbreaks of gram negative bacillus and candida infections as confirmed by molecular typing of isolates.

Artificial nails, therefore, are not recommended due to the potential detriment to hand hygiene. Additionally, hand contamination with potential pathogens is increased with ring-wearing, and jewelry should be removed prior to hand hygiene processes.

Reference: Siegel JD, Rhinehart E, Jackson M, Chiarello L, and the Healthcare Infection Control Practices Advisory Committee.Guideline for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings, June 2007.https://www.cdc.gov/hicpac/pdf/isolation/Isolation2007.pdf

WORK PRACTICE CONTROLSThe Reserve Dental Corps will implement the following work practice controls:

• Appropriate hand hygiene shall be performed before gloving and after clinical procedures.• In the absence of visible soiling of hands, approved alcohol based products for hand disinfection

may be used.• Members must sanitize their hands immediately or as soon as feasible after removal of gloves or

other Personal Protective Equipment.• Members must wash hands and any other exposed skin with soap and water, or flush mucous

membranes with water immediately or as soon as feasible following contact of such body areas with blood or OPIM.

• OSHA specifically defines saliva in dental procedures as being OPIM• If there has been no occupational exposure to or contact with blood or OPIM, the use of alcohol-

based hand cleansers would be appropriate.• Hands are to be washed before and after personal breaks for lunch, bathroom, between

patients and other purposes.• Proper donning & removal of gloves and other personal protective equipment (PPE).

• Cleaning & Disinfection of Work Surfaces.• Hand sanitizing before & after patient contact.• Minimizing or eliminating splashing, splattering, spraying and generation of droplets.• No eating, drinking, applying cosmetics or contact lenses in a patient care, clinical, or treatment

work setting. (The application of hand moisturizer/sanitizer is permitted.)

Workplace Hazard Assessment & Personal Protective EquipmentA workplace hazard assessment of the Reserve Dental Corps has determined that hazards are present which necessitate the use of Personal Protective Equipment (PPE). All member employees are required to utilize appropriate PPE as necessary to specific job tasks and hazards.

PROVISIONWhen there is the potential for occupational exposure to blood/OPIM, the Reserve Dental Corps provides PPE, at no cost to the members. Appropriate Personal Protective Equipment such as gloves, gowns, laboratory coats, face shields or masks, and eye protection, is provided to create work practice and engineering controls designed to minimize or eliminate the potential for exposure incidents.

PERSONAL PROTECTIVE EQUIPMENTPersonal Protective Equipment (PPE) is considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time for which the protective equipment is used.

“Scrubs” and similar clothing not meeting the requirements of the preceding sentence are NOT considered to be Personal Protective Equipment.

PPE TRAININGTraining in the use of the appropriate PPE for specific tasks or procedures is provided by through a cooperative initiative between the ICO, SDEs and UICOs. At a minimum PPE training shall instruct member employees on how to use them, when they are required, and what are their limitations.

The following table provides PPE selection and criteria based upon hazards and tasks:

Tasks And Procedures Hazard PPEFirst Aid procedures as applicable Exposure to Blood/OPIM

Possible Chemical ExposureMicroshield (for CPR)Exam Gloves

Performing or assisting withDental Examination

Chemical ExposureExposure to aerosol/OPIM

Gown (as necessary)Exam Gloves Splash Goggles or Safety Glasses w/side shieldsFace Masks/Face Shield

Performing (or assisting with) Dental Procedures /Laboratory Procedures

Chemical ExposureExposure to Blood/OPIMNeedlestick/Sharps Exposure

GownExam Gloves Sterile Surgical GlovesSplash GogglesSafety Glasses w/side shields

Face Masks/Face ShieldSetting Up the Dental Treatment Room (DTR)

Clean, washed hands

Disinfecting the Dental Treatment Room

Chemical ExoposureExposure to Blood/OPIM/ Needle-stick/ Sharps Exposure

GownExam GlovesSplash GogglesSafety Glasses w/side ShieldsFace Masks/Face Shield

Cleaning/Disinfecting/Sterilizing Chemical ExposureNeedlestick/Sharps Exposure

Exam Gloves Puncture resistant Rubber GlovesSafety Glasses w/side shields

Clinical Housekeeping Chemical ExposureExposure to Blood/OPIMNeedlestick/Sharps Exposure

Exam Gloves

Administering Injections Chemical ExposureExposure to Blood/OPIMNeedlestick/Sharps Exposure

Exam Gloves

Handling Specimens Exposure to Blood/OPIM Exam GlovesHandling Regulated Medical Waste Chemical Exposure

Possible Exposure to Blood/OPIM

Exam Gloves

Handling Contaminated Laundry Chemical ExposureExposure to Blood/OPIMNeedlestick/Sharps Exposure

Exam Gloves

PPE is located in the following locations:

Medical/Dental Exam Rooms Sterilization Room. NOSC Medical Department

UICOs must be notified when PPE supplies are low or if there is a question to the availability and location of PPE.

All employees using PPE must observe the following procedures:

All PPE must be removed after it becomes contaminated and before employees leave the work area.

GLOVESGloves shall be worn when it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin.

The Navy Reserve Corps utilizes single-use, disposable gloves. Never wash or decontaminate disposable gloves for reuse. Never use the same pair of gloves on subsequent patients.

Sanitize hands immediately or as soon as feasible after removing gloves or other PPE.

Disposable (single use) gloves such as surgical or examination gloves shall be replaced as soon as practical when contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised.

Heavy duty, puncture resistant, utility gloves must be worn during sterilization and recirculation of instruments. The majority of dental practice employee injury incidents occur during this job duty.

The majority of dental practice employee injury incidents occur during this job duty. Utility gloves may be decontaminated for reuse if the integrity of the glove is not compromised. However, they must be discarded if they are cracked, peeling, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised.

Clean disposable gloves should be put on before donning heavy duty utility gloves, as a protective measure. Bacterial growth/pathogens have been found on the inside of utility gloves.

MASKS, EYE PROTECTION, AND FACE SHIELDSMasks in combination with eye protection devices, such as goggles or glasses with solid side shields, or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated, and eye, nose, or mouth contamination can be reasonably anticipated. Change masks after every patient. Protective eyewear should be cleaned and disinfected after each patient use.

GOWNS, APRONS, AND OTHER PROTECTIVE BODY CLOTHINGAppropriate protective clothing such as, but not limited to, gowns, aprons, lab coats, clinic jackets, surgical caps or hoods, shoe covers or boots, or similar outer garments shall be worn in occupational exposure situations as needed. The type and characteristics will depend upon the task and degree of exposure anticipated.

Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface. Non-disposable gowns should be laundered. Laundered gowns are used one in a day or changed out if visibly soiled.

The Navy Reserve Dental Corps provides disposable gowns. These should be discarded at the end of the work day, the end of your shift, or when visibly soiled.

Housekeeping 

GENERALMember employees shall ensure that the worksite is maintained in a clean and sanitary condition. The employer shall determine and implement an appropriate written schedule for cleaning and method of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present, and tasks or procedures being performed in the area.

EQUIPMENT & WORKING SURFACESAll equipment and environmental and working surfaces in clinical or treatment areas shall be cleaned and decontaminated immediately or as soon as feasible after contact with blood or other potentially infectious materials.

Contaminated work surfaces in clinical or treatment areas shall be decontaminated with an appropriate EPA registered or FDA cleared disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious

materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.

BARRIERS & PROTECTIVE COVERINGSProtective coverings, such as plastic wrap, aluminum foil, or imperviously-backed absorbent paper used to cover equipment and environmental surfaces in clinical or treatment areas, shall be removed and replaced as soon as feasible when they become overtly contaminated or at the end of the work shift if they may have become contaminated during the shift.

REGULATED WASTEAll bins, pails, cans, and similar receptacles in clinical and treatment areas shall be cleaned and decontaminated immediately or as soon as feasible upon visible contamination.

Broken glassware which may be contaminated shall not be picked up directly with the hands. It shall be cleaned up using mechanical means, such as a brush and dust pan, tongs, or forceps.

Reusable sharps that are contaminated with blood or other potentially infectious materials shall not be stored or processed in a manner that requires employees to reach by hand into the containers where such sharps have been placed.

Regulated waste is placed in containers which are: Closable. Constructed to contain all contents and prevent leakage. Appropriately labeled or color-coded (see the following section "labels"). Closed prior to removal to prevent spillage or protrusion of contents during handling.

Contaminated sharps are discarded immediately or as soon as possible in containers that are: Closable. Puncture-Resistant. Leak Proof on Sides and Bottoms. Appropriately Labeled Or Color-Coded.

Sharps disposal containers are available in the following areas: Medical/Dental Exam Rooms Sterilization Rooms

The UICO(s) shall make sure that sharps disposal containers are to be inspected, maintained or replaced whenever necessary to prevent overfilling. Contaminated sharps containers shall be easily accessible to personnel and close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found. It is recommended that red sharps containers be mounted on a wall if kept in in the examination room. Sharps containers should never be placed in an area where the member has to bend down to access the sharps container.

LAUNDRYThe following contaminated articles will be laundered:

Laundry Items Towels Linens

The following laundering requirements must be met:

Handle contaminated laundry as little as possible, with minimal agitation. Place wet contaminated laundry in leak-proof, labeled or color-coded containers before

transport. Use (specify either red bags or bags marked with the biohazard symbol) for this purpose.

Written instructions should be posted in the area that contaminated articles will be laundered. All personnel handling contaminated laundry will observe Universal Precautions and shall wear

appropriate PPE when handling and/or sorting contaminated laundry (i.e. gloves).

LABELS Reserve Dental Corps will utilize the following labeling methods:

EQUIPMENT TO BE LABELED LABEL TYPERegulated Medical Waste Container Red Bag & Biohazard LabelSharps Container Red Container & Biohazard Label

UICOs are responsible for ensuring that warning labels are affixed, or that red bags are used as required if regulated waste or contaminated equipment is brought into the facility.

Member employees must notify their respective UICOs/supervisors as soon as they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels.

HEPATITIS B VACCINATIONAll member employees must receive the HepB vaccination.

This training will address the safety, benefits, efficacy, methods of administration, and availability of Hepatitis B vaccinations.

Vaccination will coordinated through the NOSC Medical Department or RHRP outpatient service.

MEDICAL RECORDS All members will have documented evidence in their medical record of:

1) HBV Immunization (three shot series). 2) MMR (two shot series if born after 1957).3) HIV testing (Annually for all military personnel). 4) FLU (Annually for all military personnel). 5) HAV Immunization (two shot series for military only). The SDE/Company CO will verify each

member of the dental treatment team has the proper immunizations using the Medical Readiness Recording System (MRRS) on a quarterly basis. Immunization status should be verified quarterly and reported to the Reserve Dental Infection Control Officer.

POST-EXPOSURE EVALUATION AND FOLLOW-UPShould an exposure incident occur, employees should immediately notify their respective OIC/Supervisor, the member’s home NOSC and the Command Infection Control Officer

Initial first aid shall include: Washing injury site with soap and water, without squeezing or milking the site. For eye exposures immediately go to the eye wash station and flush eyes for 15 minutes. Following immediate first aid, the following activities will be performed:

Report exposure to member’s OIC/Supervisor, member’s Home NOSC and the ICO. OIC/Supervisors will complete Exposure Control Form and forward this report to the ICO. OIC/Supervisors utilize the Exposure Report Form (Appendix C) that documents the routes of exposure and how the exposure occurred.

Injured/exposed member and source patient will report to the ER/outpatient clinic designated by their Home NOSC/ AT LOI within 20 minutes.

NOSC: NOSC Medical will direct member to selected facility for urgent care. Offsite Drill: member’s Home NOSC/CDO will direct member to selected facility. AT exercise: Member directed to facility designated in LOI for urgent care. AT clinic: Clinic will direct member to selected facility for urgent care.

Make arrangements to have the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity. Informing clinic medical staff that the injured member and source patient are there for blood testing due to Bloodborne Pathogen Exposure should allow for front of the line privileges.

If the source individual is already known to be HIV, HCV and/or HBV positive, new testing need not be performed.

Assure that the exposed member employee is provided with the source individual's test results and with information about applicable disclosure laws and regulations concerning the identity and infectious status of the source individual

Collect the exposed member employee's blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status

ADMINISTRATION OF POST-EXPOSURE

EVALUATION AND FOLLOW-UPExposed members will be offered 6 week, 3 month and 6 month follow up bloodwork coordinated through their Home NOSC’s Medical Department. The ICO ensures that health care professional(s) responsible for employee's hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA's bloodborne pathogens standard.

The member’s respective OIC/Supervisor will ensure that the health care professional(s) evaluating the member after an exposure incident receive the following:

A description of the employee's job duties relevant to the exposure incident. Route(s) of exposure. Circumstances of exposure. Results of the source individual's blood test (if possible). Relevant employee medical records, including vaccination status.

The evaluating health care professional will provide the member with a copy of the examining health care provider’s opinion within 15 days after completion of the evaluation.

PROCEDURES FOR EVALUATING THE CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENTThe ICO and SDEs will review the circumstances of all exposure incidents to determine:

Engineering controls in use at the time. Work practices followed. A description of the device being used (including type and brand). Protective equipment or clothing that was used at the time of the exposure incident (gloves, eye

shields, etc.). Location of the incident (examination room, central sterilization area, waiting room, etc.). Procedure being performed when the incident occurred. Member’s training.

The Infection Control Officer will record all percutaneous injuries from contaminated sharps in a Sharps Injury Log.

If revisions to this ECP are necessary the Infection Control Officer, will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding members to the exposure determination list, etc.)

MEMBER EMPLOYEE TRAININGAll members who have occupational exposure to bloodborne pathogens receive initial and refresher training conducted or facilitated by the Reserve Dental Corps. The training will include classroom instruction, web/computer-based training, or departmental training.

All members who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. Additionally, the training program covers, at a minimum, the following elements:

An explanation of the OSHA bloodborne pathogen standard. An explanation of the Reserve Dental Corps ECP and how to obtain a copy. An explanation of methods to recognize tasks and other activities that may involve exposure to

blood and OPIM, including what constitutes an exposure incident. An explanation of the use and limitations of engineering controls, work practices, and PPE. An explanation of the types, uses, location, removal, handling, decontamination, and disposal of

PPE. An explanation of the basis for PPE selection. Information on the Hepatitis B vaccine, including information on its efficacy, safety, method of

administration, the benefits of being vaccinated Review of the Reserve Dental Corps Bloodborne Pathogen Exposure Control Form including

appropriate actions to take and persons to contact in an emergency involving blood or OPIM. An explanation of the procedure to follow if an exposure incident occurs, including the method

of 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 to

provide for the employee following an exposure incident. An explanation of the signs and labels and/or color coding required by the standard and used at

this facility. An opportunity for interactive questions and answers with the person conducting the training

session.

RECORDKEEPINGSDEs will forward NAVRES 3500/2 Records of Training to the ICO for each member upon completion of training.

The training records include: The dates of the training sessions. The contents or a summary of the training sessions. The names and qualifications of persons conducting the training. The names, ranks and unit affiliation of all persons attending the training sessions.

Member training records are provided upon request to the member or the member's authorized representative within 15 working days.

MEDICAL RECORDSIndividual Medical Records (IMRs) are maintained for each member employee with occupational exposure in accordance with 29 CFR 1910.1020, "Access to Employee Exposure and Medical Records." The SDE/Company CO will verify each member of the dental treatment team has the proper immunizations using the Medical Readiness Recording System (MRRS) on a quarterly basis. Immunization status should be verified quarterly and reported to the Reserve Dental Infection Control Officer.

OSHA RECORDKEEPINGAn exposure incident is evaluated to determine if the case meets OSHA's Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by the Infection Control Officer.

SHARPS INJURY LOGIn addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a Sharps Injury Log. All incidences must include at least:

Date of the injury. Type and brand of the device involved (syringe, suture needle). Department or work area where the incident occurred. Explanation of how the incident occurred.

This log is reviewed as part of the annual program evaluation and maintained for at least five years following the end of the calendar year covered. If a copy is requested by anyone, it must have any personal identifiers removed from the report.

Appendix A: DefinitionsBLOODBORNE PATHOGENS: Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV).

CONTAMINATED: The presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.

CONTAMINATED LAUNDRY: Laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.

CONTAMINATED SHARPS: Any contaminated object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires.

ENGINEERING CONTROLS: Controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.

EXPOSURE INCIDENT: 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.

OCCUPATIONAL EXPOSURE: Means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.

OTHER POTENTIALLY INFECTIOUS MATERIALS (OPIM):

1) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all

body fluids in situations where it is difficult or impossible to differentiate between body fluids;

2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and

3) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

PERSONAL PROTECTIVE EQUIPMENT: Specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes (e.g., uniforms, pants, shirts or blouses) not intended to function as protection against a hazard are not considered to be personal protective equipment.

REGULATED WASTE: Liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials.

STANDARD PRECAUTIONS: Guidelines recommended by the Centers for Disease Control and Prevention for reducing the risk of transmission of blood-borne and other pathogens in hospitals. The standard precautions synthesize the major features of universal precautions (designed to reduce the risk of transmission of blood-borne pathogens) and body substance isolation (designed to reduce the risk of pathogens from moist body substances) and apply them to all patients receiving care in hospitals regardless of their diagnosis or presumed infection status. Standard precautions apply to

1) blood;

2) all body fluids, secretions, and excretions except sweat, regardless of whether or not they contain blood;

3) non-intact skin; and 4) mucous membranes.

The precautions are designed to reduce the risk of transmission of microorganisms from both recognized and unrecognized sources of infection

in hospitals. UNIVERSAL PRECAUTIONS: Universal precautions is an approach to infection control to treat all human blood and certain human body fluids as if they were known to be infectious for HIV, HBV and other bloodborne pathogens.

Appendix B: Bloodborne Pathogen Exposure Control Protocol

Blood & Body Fluid Exposure Control Protocol Perform the steps below following an exposure incident involving blood or body fluid.

STEP ONE: IMMEDIATELY wash injury site with soap and water. Do not squeeze or milk the site. Eye exposures immediately go to the eye wash station and flush eyes for 15 minutes.

STEP TWO: IMMEDIATELY report mishap to Supervisor, Member’s Home NOSC and Command Infection Control Officer (CICO)

STEP THREE: The affected provider and source patient will report to the ER or clinic designated by the member’s home NOSC / AT LOI within 20 minutes. Inform the medical staff that the victim and source patient are there for blood testing due to Bloodborne Pathogen Exposure. This should allow for front of line privileges.

LOCATION & CARE: NOSC: NOSC medical staff will direct member to facility of choice for urgent care.

OFFSITE DRILL: Contact Member’s Home NOSC / CDO who will direct member to facility of choice for urgent care.

AT EXERCISE: Contact medical support, who will direct member to facility designated in LOI for urgent care.

AT CLINIC: Clinic will direct member to facility of choice for urgent care.

FOLLOW-UP: Personnel should be offered 6 week, 3 and 6 month follow up bloodwork coordinated thru their home NOSC Medical Department

Appendix C: Exposure Report Form

Appendix D: Hazard Communication StandardsStandards The globally harmonized system of classification and labelling of chemicals. The GHS is an international approach to hazard communications, providing agreed upon criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets.

HAZARD COMMUNICATION SAFETY DATA SHEETS (OSHA) The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below:

SECTION 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

SECTION 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

SECTION 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

SECTION 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.

SECTION 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

SECTION 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

SECTION 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.

SECTION 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

SECTION 9, Physical and chemical properties lists the chemical's characteristics.

SECTION 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.

SECTION 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

SECTION 12, Ecological information*

SECTION 13, Disposal considerations*

SECTION 14, Transport information*

SECTION 15, Regulatory information*

SECTION 16, Other information, includes the date of preparation or last revision.

 *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)). Employers must ensure that SDSs are readily accessible to employees. See Appendix D of 1910.1200 for a detailed description of SDS contents. For more information: www.osha.gov

Appendix E: Hazard Communication Standard labels

HAZARD COMMUNICATION STANDARD LABELSOSHA has updated the requirements for labeling of hazardous chemicals under its Hazard Communication Standard (HCS). As of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. A sample revised HCS label, identifying the required label elements, is shown on the right. Supplemental information can also be provided on the label as needed.

SAMPLE LABEL:

Product IdentifierCODE ______________________________Product Name _______________________

Supplier IdentificationCompany Name_________________Street Address ______________________City _________________ State ______Postal Code __________ Country ______Emergency Phone Number ___________

Precautionary StatementsKeep container tightly closed. Store in cool, well ventilated place that is locked.Keep away from heat/sparks/open flame. No smoking.Only use non-sparking tools. Use explosion-proof electrical equipment.Take precautionary measure against static discharge. Ground and bond container and receiving equipment. Do not breathe vapors. Wear Protective gloves. Do not eat, drink or smoke when using this

product. Wash hands thoroughly after handling. Dispose of in accordance with local, regional, national, international regulations as specified.

In Case of Fire: use dry chemical (BC) or Carbon dioxide (CO2) fire extinguisher to extinguish.

First AidIf exposed call Poison Center.If on skin (on hair): Take off immediately any contaminated clothing. Rinse skin with water.

Hazard Pictograms

Signal WordDanger

Hazard StatementHighly flammable liquid and vapor.May cause liver and kidney damage.

Supplemental InformationDirections for use__________________________________________________________________________________________Fill weight: _____________ Lot Number ______Gross weight: __________ Fill Date: ______Expiration Date: ___________

U.S. Department of Labor | Occupational Safety & Health Administration | 200 Constitution Ave., NW, Washington, DC 20210 | Telephone: 800-321-OSHA (6742) | TTY: 877-889-5627

HAZARD COMMUNICATION STANDARD PICTOGRAMAs of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.

HCS PICTOGRAMS AND HAZARDS

HEALTH HAZARD

CarcinogenMutagenicity

Reproductive ToxicityRespiratory SensitizerTarget Organ Toxicity

Aspiration Toxicity

FLAME

FlammablesPyrophoricsSelf-Heating

Emits Flammable GasSelf-Reactives

Organic Peroxides

EXCLAMATION MARK

Irritant (skin and eye)Skin SensitizerAcute Toxicity

Narcotic EffectsRespiratory Tract Irritant

Hazardous to Ozone Layer (Non-Mandatory)

GAS CYLINDER

Gases Under Pressure

CORROSION

Skin Corrosion/BurnsEye Damage

Corrosive to Metals

EXPLODING BOMB

ExplosivesSelf-Reactives

Organic Peroxides

FLAME OVER CIRCLE

Oxidizers

ENVIRONMENT(Non-Mandatory)

Aquatic Toxicity

SKULL AND CROSSBONES

Acute Toxicity (fatal or toxic)

OSHA Safety & Health Management System GuidelinesTo assist employers and employees in developing effective safety and health programs, OSHA published recommended Safety and Health Program Management Guidelines (Federal Register 54 (16): 3904-3916, January 26, 1989). These voluntary guidelines can be applied to all places of employment covered by OSHA.

The guidelines identify four general elements critical to the development of a successful safety and health management system:

Management leadership and employee involvement. Workplace analysis. Hazard prevention and control. Safety and health training.

The guidelines recommend specific actions, under each of these general elements, to achieve an effective safety and health program. The Federal Register notice is available online at www.osha.gov.

INFORMATION AVAILABLE ELECTRONICALLYOSHA has a variety of materials and tools available on its website at www.osha.gov. These include e-Tools such as Expert Advisors, Electronic Compliance Assistance Tools (e-cats), Technical Links; regulations, directives, publications; videos, and other information for employers and employees. OSHA's software programs and compliance assistance tools walk you through challenging safety and health issues and common problems to find the best solutions for your workplace.

OSHA PUBLICATIONSOSHA has an extensive publications program. For a listing of free or sales items, visit OSHA's website at www.osha.gov or contact the OSHA Publications Office, U.S. Department of Labor, 200 Constitution Avenue NW, N-3101, Washington, DC 20210. Telephone (202) 693-1888 or fax to (202) 693-2498.