1. Exposure Control Plan
2. Universal Precautions
3. OSHA exposure determination
4. Post-exposure Management
5. Hepatitis B Immunization
6. Record Keeping

1. Exposure Control Plan

1. Each dental office shall have a written exposure control plan that clearly describes how the office complies with the BBP Standard.
2. The Exposure Control Plan must be accessible to employees and updated at least annually, or when there are significant changes to procedures or processes.

2. Universal Precautions

The Universal Precautions’ primary concern is for the Health and Safety of employees in the DHS.

1. OSHA created the term Universal Precautions, which is the concept that all human blood and certain bodily fluids are treated as if they are infected with blood-borne pathogens.
2. Universal Precautions extend the CDC’s standard precaution to include all body fluids, secretions, and excretions.
3. The reason to practice Universal Precautions is that it is impossible to know which patients may carry blood-borne pathogens, therefore all DHCP should treat every patient as if they were infected.

3. OSHA Exposure Determination

OSHA categorizes employees by the risks associated with their job functions.

• Category I: Routinely exposed to blood, saliva, and OPIM (Dentist, assistant, hygienist, lab technician)
• Category II: May occasionally be exposed to blood, saliva and OPIM (front office employee that may occasionally disinfect an operatory after patient treatment, process contaminated instrument or x-rays and/or is trained in CPR).
• Category III: Never exposed to blood, saliva and OPIM, never touches patient care items or clinical surfaces (Office manager, administrative assistant)

4. Post-exposure Management

Even with precautionary measures in place, exposure incidents do happen; therefore, the BBPS requires employers to have a written plan that explains the steps and procedure to follow if an employee has an Exposure Incident (see Section 5).

5. Hepatitis B Immunization

Employers must offer the HBV vaccination series to all category I & II (high risk & medium risk) employees immediately once hired.

1. Right of refusal
   1. The employee, however, has the right to refuse the vaccination for any reason. If the employee refuses the vaccine, s/he must sign a Declination form.
   2. If the employee changes his/her mind at a later time, the employer must provide the Hepatitis B vaccination series at no cost to the employee
2. The employer shall not make participation in a prescreening program a prerequisite for receiving the Hepatitis B vaccination or for hiring the employee.
3. The vaccination process
   1. The Hepatitis B vaccine comes in a series of three separate injections. These must be taken in the specified order.
   2. If the second or third injection of the series is missed, the employee must start over.
   3. In order to know if the employee is protected, a blood test for Hepatitis B antibodies should be done one – two months after the final vaccine injection of the series is given.
   4. For the few people who do not form antibodies, a second series of injections can be taken to improve the response.
   5. People who do not respond to the vaccine after the second series should be warned that they may be susceptible to the Hepatitis B virus.

6. Record Keeping

1. Employers are required to keep confidential employee medical records for all employees for the length of employment, and for an additional 30 years following end of employment if an Exposure Incident happened during employment.
   1. Medical records must include:
      1. A file folder with the employees first and last name
      2. The employee’s social security number
      3. The signed Hepatitis B Declination form (if applicable)
      4. Current proof of immunity to Hepatitis B
      5. Dates of the vaccines
      6. Records of exposure and post-exposure follow up
   2. The only person/s having access to this file is the employer and the designated Safety Manager
2. Training Records: Employers must keep records documenting that they have provided employees with OSHA required training
   1. Employers are required to provide employees with initial Bloodborne Pathogen and Office Safety training, and then annual Bloodborne Pathogen training
   2. OSHA requires the required training be done during regular office hours at no cost to the employee
   3. Documentation of trainings must be kept in the office Exposure Control Plan for at least three years