Your Best Pathway to Health
Exposure Control Plan
Your Best Pathway to Health is committed to providing a safe and healthful work environment for our volunteers. This exposure control plan (ECP) is provided to eliminate or minimize exposure to Blood-borne Pathogens. The ECP is a key document to assist in protecting our volunteers. This ECP includes:
Determination of volunteer staff exposure
Implementation of various methods of exposure control, including
- Universal/Standard precautions
- Engineering and work practice controls
- Personal protective equipment
Hepatitis B vaccination
Post Exposure evaluation and follow up
Communication of hazards and training
Procedures for evaluating circumstances surrounding and exposure incident
The methods of implementation of these elements are discussed in the subsequent pages of this ECP.
• The Clinic Director or his/her designee is responsible for the implementation of the ECP. The Clinic Director or his/her designee will maintain, review and update the ECP when necessary to include new or modified tasks and procedures.
• Those who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP.
• The Clinic Director or his/her designee will maintain and provide all necessary personal protective equipment (PPE), engineering controls (e.g. sharps containers), labels and red bags. The Clinic Director or his/her designee will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes.
• The Clinic Director or his/her designee is responsible for ensuring that medical actions are performed to maintain appropriate volunteer health.
• The Clinic Director is responsible for training, documentation of training, and making the written ECP available to staff.
Volunteer Staff Exposure Determination
The following is a list of all volunteer classifications at our events in which all have or may have Blood-borne pathogen exposure:
• Dental Hygienist
• Dental Assistant
• X-ray Technician
• Physician Assistant
• Nurse Practitioner
• Nursing student
• Environmental Services
Methods of Implementation and Control
All volunteers will utilize universal precautions
Exposure Control Plan
Volunteers will receive an explanation of this ECP during their initial training session. It
will also be reviewed as needed. All volunteers will have an opportunity to review this
plan at any time during their shifts, by contacting the Clinic Director or his/her designee.
If requested, we will provide volunteers with a copy of the ECP at no charge.
The Clinic Director or his/her designee is responsible for reviewing and updating the
ECP to reflect any new or modified tasks and procedures which affect blood-borne
pathogen exposure and reflect new or revised positions with blood-borne pathogen
Engineering Controls and Work Practices
Engineering controls and work practices will be used to prevent or minimize exposure to
blood-borne pathogens. The specific engineering controls and work practice controls
are listed below:
• Eye wear with shields or full faces shields are to be used for surgeries
• Masks are to be used for surgeries
• Gloves are to be used
• Protective gown with long sleeves must be worn when the following equipment is used: slow speed and high-speed hand pieces, air water syringe, ultrasonic cleaner; also, during operator clean up and instrument processing
• Gloves must be worn whenever touching liquid human products such as blood and saliva, surgical gloves will be worn for surgery, exam gloves for regular operative procedures, and utility gloves for clean up when touching something wet or contaminated
• Personal protective equipment will not protect from sharps injuries
• Sharps are to be placed in sharps containers as soon as possible after use
• Instruments are to be passed carefully
• Use cotton pliers and hemostats to handle sharps. Use gloves to reduce your risk to exposure
• Sharps disposal containers are to be inspected and maintained by department staff and changes whenever necessary to prevent overfilling.
Changes in engineering control and work practices will be identified through review of incident reports, volunteer interviews and staff meetings. The Clinic Director or his/her designee will ensure implementation of these recommendations.
Personal Protective Equipment (PPE)
PPE is provided to our volunteers at no cost to them. If there is not an appropriate or adequate size of PPE available for you, contact the Clinic Director or his/her designee.
All volunteers using PPE must observe the following precautions:
• Wash hands immediately or as soon as feasible after removal of gloves or other PPE
• Remove PPE after it becomes contaminated, and before leaving the work area
• Disposable used PPE may be placed in lined waste containers for later disposal
• Wear appropriate gloves when it can be reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctured, contaminated, or if their ability to function as a barrier is compromised
• Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing or deterioration
• Never wash or decontaminate disposable gloves for reuse
• Wear appropriate face and eye protections when splashes, sprays, splatters, or droplets of blood or other OPIM pose a hazard to the eye, nose, or mouth
• 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
• Do not wear soiled PPE in lunch or other clean areas. (Also, do not touch clean areas with Dirty PPE). Remove PPE after it becomes contaminated, and before leaving the work area
The procedure for handling used PPE is as follows:
• Face shields and eyewear may be sprayed with soap and water or a disinfectant and then rinsed and dried between uses
• Single use gloves and masks are to be disposed of between each patient use
• Heavy duty nitrile gloves may be washed with soap and water and autoclaved
• Used resuscitation equipment is disposable and may not be reused.
Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color coded, and closed prior to removal to prevent spillage or protrusion of contents during handling.
Sharp disposal containers will be removed and disposed as specified.
Regulated waste will be removed and disposed as specified.
Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms and labeled or color-coded appropriately. These containers must be easily accessible and as close as feasible to the immediate area where sharps are used. Bins and pails (e.g., wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination.
Broken glassware which may be contaminated is picked up using mechanical means, such as a brush and dust pan.
Laundry - All PPE is disposable; no laundering will be performed
Labels - All laboratory dental cases that have not been decontaminated must be accompanied by a biohazard label when leaving the facility. All sharps containers must be marked with a biohazard label. The ultrasonic machine must be marked with a biohazard label. Dirty instrument containers must be marked with a biohazard label.
Hepatitis B Vaccination
By volunteering as a health care provider, whether excluded from licensure from the state in which the event is held or not, each individual health care provider acknowledges compliance with the state requirements of their respective States Law in regards to vaccinations for licensure and or certification within their jurisdictions.
Post Exposure Evaluation and Follow Up
Should an exposure incident occur, contact the Clinic Director or Medical Director.
An immediate confidential medical evaluation and follow up will be conducted by the Medical Director or his/her designee. Following the initial first aid (clean the wound, flush eyes or mucous membranes, etc.) the following activities will be performed:
• Document the routes of exposure and how exposure occurred
• Identify and document the source individual (unless the staffer can establish that identification is infeasible or prohibited by state or local law).
• Obtain consent and make arrangements to have the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity; document that the source individual's test results were conveyed to the staff member. (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 volunteer is provided with the source individual's test results and with information about applicable disclosure laws and regulations concerning the identity and infectious state of the source individual (e.g. laws protecting confidentiality)
• After obtaining consent, collect exposed volunteer's blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status
• If the volunteer does not give consent for HIV serological testing during collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days; if the exposed volunteer elects to have the baseline sample tested during the waiting period, perform testing as soon as feasible.
Administration of Post-Evaluation and Follow-Up
The Clinic Director ensures that the health care professional responsible for volunteer's evaluation and follow up is supplied with information about blood borne pathogens.
The Clinic Director ensures that the health care professional evaluating a volunteer after an exposure incident receives the following:
A description of the volunteer's duties relevant to the exposure incident
Route(s) or exposure
Circumstances of exposure
If possible, results of the source individual's blood test
Relevant staff medical records, including vaccination status
The volunteer should be provided with a written opinion of the evaluating health care professional within 15 days after the completion of evaluation.
Procedures for Evaluating the Circumstances Surrounding an Exposure Incident
The Clinic Director or his/her designee 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
• Protective equipment or clothing that was used at the time of the exposure incident (gloves, eye shields, etc.)
• Location of the incident (work station, sterilization), etc.
• Procedure being performed when the incident occurred
• Volunteer's training
If it is determined that revisions need to be made the Clinic Director (or designee) will ensure that appropriate changes are made to this ECP. (Changes may include an evaluation of safer devices, etc.)
All volunteers who have exposure to blood borne pathogens receive training conducted by the Clinic Director (or designee).
Records are kept of volunteers completing review.