3 - Exposure Control Plan

The Exposure Control Plan (ECP) for the College of Dentistry (COD) is designed to protect all workforce members from potential exposure to bloodborne pathogens, including Human Immunodeficiency virus (HIV), Hepatitis B virus (HBV), and Hepatitis C virus (HCV). The COD follows the Centers for Disease Control and Prevention (CDC), Organization for Safety and Asepsis Procedures (OSAP), OSHA, and the University of Oklahoma Health Sciences Center (OUHSC) Infectious Disease Policy (HSC/OU-Tulsa Infectious Disease Policy (ouhsc.edu) recommendations and guidelines for infection control.

Purpose: The purpose of this document is to establish procedures for prevention, response to exposure incidents, and proper handling of Other Potentially Infectious Materials (OPIM) in accordance with OSHA standard 29 CFR 1910.1030. 

The following ECP is provided to eliminate or minimize WM occupational exposure to blood, bloodborne pathogens, or OPIM. This document is a key policy to assist in implementing and ensuring compliance with the standard, thereby protecting all WM and patients receiving care. This ECP includes:

• WM exposure determination
• Implementation of various methods of exposure control, including:
  • Standard Precautions
  • Transmission-based Precautions
  • Personal Protective Equipment (PPE)
  • Work Practice Controls
  • Management of Sharps
  • Sharps Injury Log
  • Instrument Handling
  • Handpieces
  • Engineering Controls
  • Housekeeping and Spill Cleanup
  • Labels
• Hepatitis B Vaccination
• Training
• Recordkeeping and documentation
• Waste Disposal
• Post-exposure Evaluation
• Exposure Incident Procedures
• Post-exposure Follow-up

The policy statements in this document apply to all patients treated or evaluated within the College of Dentistry.

This policy applies to faculty, staff, administrators, residents, fellows, students, and/or volunteers of all College of Dentistry facilities and programs. All references within this document to “Workforce Members” (WM) mean faculty, staff, administrators, residents, fellows, students, and/or volunteers who are WM of the University who have the potential for exposure to patients and/or to infectious materials, including bodily substances, contaminated medical supplies and equipment, contaminated environmental surfaces, or contaminated air.

All WM are expected to be thoroughly familiar with these guidelines and to apply them in every instance of patient care.

The COD Director of Compliance is responsible for:

•    Implementation and maintenance of the ECP. The ECP will be reviewed and updated as necessary, at a minimum annually.
•    Availability of the ECP to WM, OSHA, and NIOSH representatives. 
•    Determination of WM who have occupational exposure to blood or OPIM must comply with the procedures and practices outlined in this ECP.
•    Maintenance and provision of all necessary PPE, engineering controls (sharps containers), labels, and red bags as required by the standard; will ensure that adequate supplies of PPE are available in the appropriate sizes.
•    Ensuring all medical actions required by the standard are performed and appropriate OU Health Employee Health clinic, OUHSC/OU Tulsa Student Health clinic, designated medical facility, and/or OSHA records are maintained. 
•    Ensuring completion of annual refresher training from OnPoint and maintaining training documentation for WM.

The following classification of WM who are directly involved in patient care and have an increased risk of occupational exposure include, but are not limited to, dentists, residents, hygienists, dental assistants, dental personnel, sterilization technicians, clinical laboratory personnel, non-student trainees, students, and/or volunteers.

The following classification of WM who are not directly involved in patient care but may be at risk of occupational exposure include, but are not limited to, clinical clerical staff, clinical housekeeping, clinical maintenance, clinic administration, clinic billing staff, Dental Informatics staff, Information Technology staff, laundry, and police and security personnel.

All WM will be instructed on and must follow standard precautions to control infectious diseases when in direct contact with body fluids. WM must treat body fluids as if they are known to be infectious.

Body fluids are identified as blood, semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, peritoneal fluid, amniotic fluid, saliva, urine, feces, nasal secretions, sputum, vomit, breast milk, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult to or impossible to differentiate between body fluids.

Standard precautions include:

1. WM must wash hands for 40 – 60 seconds between contact with each patient, even if gloves have been used, and after removing gloves.
2. WM must wear gloves during any patient contact when contact with body fluids is likely to occur.
3. WM are required to obtain and use the appropriate PPE based on anticipated exposure and appropriate for the procedure being performed.

• At a minimum the correct PPE should include:
  • Gloves
  • Eye Protection
  • Mask
  • Gown (optional)

4. WM are required to clean up blood and body fluids promptly with an EPA-approved disinfectant.

Transmission-based Precautions are the second tier of basic infection control and are used in addition to Standard Precautions for patients who may be infected or colonized with certain infectious agents for which additional precautions are needed to prevent infection transmission.

Transmission-based precautions include:

1. Use Contact Precautions for patients with known or suspected infections that represent an increased risk for contact transmission.
2. Use Droplet Precautions for patients with known or suspected to be infected with pathogens transmitted by respiratory droplets that are generated by a patient who is coughing, sneezing, talking, or dental aerosols.
3. Use Airborne Precautions for patients known or suspected to be infected with pathogens transmitted by the airborne route (e.g., tuberculosis, measles, chickenpox, disseminated herpes zoster).

All PPE is provided to WM at no cost to the WM. PPE will be the correct size, clean, in good repair, and fit properly. PPE is designed to protect the skin and mucous membranes of the eyes, nose, and mouth from blood or OPIM. Spray and aerosol from handpieces and air-water syringes, patient coughs, and other activities in the operatory are possible sources of pathogens. 

Required PPE includes:

1. Eye protection devices, such as goggles or glasses with solid side shields or chin-length face shields, must be worn whenever splashes, sprays, splatters, or droplets of blood or OPIM may be generated, and eye contamination can be reasonably anticipated. Eyewear must be cleaned and disinfected between patients. Protective eyewear is required for the patient to protect their eyes from debris.
2. ASTM Level III surgical masks that cover both nose and mouth must be worn whenever reasonable anticipation of the production of aerosols or splatters of microorganisms exists. Masks are to be changed if wet or visibly soiled and between patients. Do not wear masks under the chin or dangling around the neck.
3. N95 respirators are optional. Respirator fit testing must be completed before wearing and annually, thereafter, if an N95 respirator is to be worn for your protection. 
4. Long-sleeve disposable over-gowns will be worn for all aerosol-generating clinical procedures. Gowns should be changed if torn or visibly soiled. Gowns should be removed before leaving the treatment areas and, under no circumstances, worn outside the clinic area, including the waiting room, patient checkout offices, or restrooms. Street clothes, work clothes, or scrubs worn under over-gowns are not considered personal protective equipment.
5. Single-use disposable, non-latex gloves will be worn for all clinical procedures when there is reasonable anticipation of encountering mucus membranes or OPIM. Patient exam gloves are worn for non-surgical procedures. Sterile surgical gloves will be worn for all surgical procedures, e.g., periodontal surgery, oral surgery, and implant placement. If leaving the operatory during patient care, gloves must be removed and discarded or protected with over gloves.
6. Head covers are optional. If worn, they must cover the entire head, and all hair must be covered. The fabric must be washable; the material cannot have inappropriate content. Head covers can only be worn for one day and WM is responsible for laundering, if not disposable.
7. Face shields are worn if eyewear does not have appropriate side shields. 
8. PPE that is soaked with blood or OPIM should be placed in a designated container labeled biohazard trash.

The following work practice controls will be used:

1. Disposable barriers will be placed whenever possible to cover contact surfaces. This includes light handles, light switches, chair controls, chair handles, patient chairs, slow-speed suction, air/water syringes, HVE, keyboards, mice, and x-ray equipment. Barriers include plastic wrap, bags, adhesive wrap, and other moisture-impervious materials. Use personal protective equipment (PPE) when disposing of contaminated barriers. Refer to the Proper Dental Unit Set-up with Barriers posters found in all clinical faculty offices.
2. A debris bag should be available at each dental unit to discard all medical waste. Waste that was generated that has significant amounts of blood or saliva (drips when squeezed) must be disposed of in the waste receptacle labeled with a RED biohazard sticker, provided in each clinic.
3. Contaminated needles and sharps will never be sheared off or purposely broken. After each use, recap needles using the one-handed scoop technique or a protector card for recapping used dental needles. Sharps must be placed in RED sharps containers located at each dental unit.
4. Disinfect using the wipe-discard-wipe technique with an Environmental Protection Agency (EPA) registered intermediate-level hospital disinfectant on all patient contact surfaces that do not have a barrier in place. If the barrier becomes compromised, then use the wipe-discard-wipe technique. Allow the disinfectant to sit on the surfaces for the manufacturer’s recommended time, usually 3 minutes. Non-sterilizable equipment used during procedures (e.g., amalgamators, torches,) must be disinfected between patients. Curing lights need to be disinfected or have a barrier put in place.
5. While wearing PPE, at the beginning of each appointment, flush air/water lines, ultrasonic scaler lines, and handpiece lines for 30 seconds.
6. Dental unit waterlines are treated to control biofilm and reduce micro-bacterial count in operatory aerosol and spatter. All dental units have self-contained water systems. Clean gloves must be worn when refilling the unit water bottle. Use ICX® treated water from the designated water sources. The ICX® tablet maintains water quality for up to two weeks.
7. Disinfect removable appliances, alginate impressions, blue bite impressions, and PVS impressions with the Clorox Healthcare Fuzion disinfectant located at each dental unit for the recommended contact time of 3 minutes. Rinse with water before transporting or working in the clinical laboratory.
8. Extracted teeth without amalgam restoratioins are considered biohazardous and are placed into the biohazard trash. Extracted teeth with amalgam restorations are placed into the amalgam waste container for proper disposal.
9. For clinical lab safety, wear proper PPE when performing laboratory procedures. Secure hair and loose clothing to minimize the potential for cross-contamination and injury. When using the polishing lathe, always use fresh pumice, a clean disposable tray, and a sterile rag wheel.
10. Hair should be secured away from the face so that it does not interfere with or become contaminated during procedures. 
11. Eating, drinking, applying cosmetics or lip balm, and handling contact lenses are prohibited in areas where a reasonable likelihood of exposure to blood or OPIM can happen. Food and beverages should not be kept in refrigerators or freezers where patient products, blood, or OPIM are stored.
12. WM must adhere to good hand hygiene practices following CDC recommendations. Hand washing with soap and water for 40-60 seconds must occur before donning gloves at the beginning of the day. WM must wash their hands (if visibly soiled) or use hand sanitizers immediately after removing contaminated gloves and before donning another pair.
13. Use over-gloves or remove gloves when leaving the operatory to prevent cross-contamination.
14. All instruments must be sterilized between patients including high-speed handpieces, slow-speed attachments, dental hygiene prophy angles, ultrasonic tips, and ultrasonic handpieces. Each morning Central Sterilization (CS) performs a Bowie Dick test on the autoclaves. Every load from CS utilizes a challenge pack and is checked before releasing the load for patient use. The CS autoclaves undergo biological monitoring once a week. Each clinic's autoclave undergoes weekly biological monitoring.
15. All contaminated, reusable instruments or equipment must be turned into the “dirty” instrument tubs in each clinic. The CS staff will retrieve the tubs in a closed-case cart preventing cross-contamination. Uncovered contaminated equipment is not allowed outside of clinical areas. 
16. All checked-out student instrument kits must be turned in to CS at the end of each day. Students must not store any sterilized items in their clinic locker.

1. Contaminated sharps must be discarded immediately in puncture-resistant, sealable, leakproof containers, and adequately labeled as sharps.
2. Each dental unit is supplied with a sharps container. Containers should be kept upright and checked periodically to prevent overfill.
3. Contaminated needles and sharps shall not be sheared or purposely broken. Needles must be recapped after each use. Recapping needles is allowed for procedures requiring more than one administration of anesthesia. In such cases, a one-handed scoop technique or protector card is required.

Sharps include the following:

1. Dental needles
2. Anesthetic carpules
3. Broken glass
4. Lab blades
5. Surgical blades
6. Endodontic files
7. Burs
8. Dental Instruments
9. Gates-Glidden or any other endodontic preparatory instruments

1. A sharps injury log will consist of the required OSHA Form 300 log and a document containing information from the OU Environmental Health and Safety Office.
2. 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. 
3. If a copy of the documentation is requested, all personal identifiers must be removed from the report.

1.    Wipe instruments carefully with a damp gauze during treatment to eliminate debris from drying.
2.    Secure all instruments inside the cassette to prevent sharps exposure.
3.    Place instrument cassettes in tubs provided in each clinic.
4.    All contaminated equipment must be turned into the “dirty” tubs provided for disinfection or sterilization.
5.    Central Sterilization (CS) staff will transport all cassettes to CS in a closed instrument case cart.
6.    The transportation of open, contaminated cassettes to CS is prohibited.

1. All components of the electric handpieces must be sterilized between uses.
2. Wipe the attachments used for patient care with disinfectant wipes. Allow to stand for the appropriate contact time.
3. While wearing clean gloves, take the attachments to the dry lab for cleaning and lubrication at the designated station.
4. Dental hygiene cordless handpieces require the sleeve to be sterilized between uses. The motor has a barrier placed between the sleeve and the motor. 

The following engineering controls will be used to eliminate or minimize WM exposure to bloodborne pathogens or OPIM:

1. Autoclaves will be used to sterilize reusable sharp instruments in clinical settings.
2. Dental dams or Isovacs will be used in patient procedures when necessary to reduce aerosolization to WM.
3. Hand washing and hand sanitizing facilities are available to all WM with potential bloodborne pathogen exposure. Facilities are available at each operatory, in all clinics, dispensaries, and laboratories.
4. High-volume evacuation (HVE), dental dam or Isovac utilization, and proper patient positioning will be used to reduce exposure to blood or OPIM droplets.
5. Instrument cassettes are completely enclosed, reducing the handling of reusable contaminated sharps. WM are responsible for securing instruments inside the cassettes before turning them into CS for decontamination and sterilization.
6. Sharps containers are available at each operatory and are to be used for all disposable sharps which include, but are not limited to, needles, scalpels, files, burs, and anesthetic carpules.
7. Instrument washers/disinfectors and ultrasonic cleaners will be used to reduce WM from handling contaminated sharp instruments. Dispensary and CS personnel are responsible for monitoring the effectiveness of the equipment and reporting problems as needed.
8. Eyewash stations are available in every clinic and laboratory following ANSI and OSHA standards for workplace exposures.

WM should ensure clinical areas are maintained in a clean and sanitary manner. All equipment and patient-contact surfaces shall be decontaminated as soon as possible after contact with blood or OPIM.

The following procedures should be taken in the event of spills:

1. Standard precautions must be observed. Cleaning of spills must be limited to those people who are trained for the task.
2. Only disposable towels should be used to avoid difficulties involved with laundering.
3.  Blood or OPIM spills: 
   1. Alert people in the immediate area of the spill
   2. Put on PPE – mask, eyewear, gloves, and over-gown
   3. Cover the spill with paper towels or absorbent materials
   4. Carefully pour EPA-registered disinfectant on the surface and begin to clean up the spill
   5. Allow the disinfectant to be in contact with the surface for the manufacturer’s recommended contact time
   6. Discard all materials into a biohazard red bag for disposal

For additional information, click the link: Policy for Waste Disposal and Spills 

1. If the warning label method is selected, the warning labels shall be affixed to containers of regulated waste, refrigerators, and freezers containing blood or OPIM, and other containers used to store, transport, or ship blood or OPIM.
   1. The label shall be fluorescent orange or orange-red with lettering and symbols in a contrasting color.
   2. The label will be affixed as close to the container as possible in a manner that prevents unintentional removal.
   3. Per OSHA, red bags or red containers may be substituted for labels.
   4. Regulated waste that has been decontaminated does not need to be labeled or color-coded.
2. If the red bag or red container method is selected, the facility will need to stay consistent throughout to avoid confusion.
   1. The above items will primarily apply to the red-regulated medical waste containers located throughout the facility.
   2. Pre-labeled biohazard containers will not have the labels removed.
   3. Pre-labeled containers are primarily sharps containers and containers designed for transport.

For employees:

1. OU Health Employee Health will provide Hepatitis B education to employees on vaccinations, addressing safety, benefits, efficacy, administration methods, and availability during the New Hire Prescreening process.
2. The Hepatitis B vaccination series is available at no cost after initial employee screening and within 10 days of initial assignment to the exposure determination section of this policy. Vaccination is encouraged unless the following occurs:
   1. Documentation exists that the WM has previously received the series.
   2. Antibody testing reveals that WM is immune.
   3. The medical evaluation shows that vaccination is contraindicated.
3. If an employee declines the vaccination, the employee must sign an HBV vaccine accept/declination form. Employees who refuse may request and obtain the vaccination later at no cost to them. Documentation of refusal of the vaccination is kept at OU Health Employee Health.
4. Following the medical evaluation, a copy of the health care professional’s written opinion will be obtained and provided to the WM within 15 days of completion of the assessment. It will be limited to whether the employee requires the Hepatitis B vaccine and whether the vaccine was administered.

For students:

1. The COD Office of Compliance will provide Hepatitis B education to students on vaccinations, addressing safety, benefits, efficacy, administration methods, and availability during Student Orientations.
2. Students are responsible for the costs associated with the administration of Hepatitis B vaccinations, boosters, or titers.
3. If a student declines the vaccination, the student must sign a vaccination declination form and have it approved by the appropriate OUHSC department. Documentation of the vaccination declination is kept within the Complio Immunization Compliance program.

Annual training for Bloodborne Pathogens is located at https://onpoint.ou.edu/ Training certifications are generated for each WM upon successful completion of the course.

For employees:
The documentation will be stored within OnPoint’s Training Transcript or the WM Self-Service System within the Training Summary.

For students:
The documentation will be stored within OnPoint’s Training Transcript and the Complio Immunization Compliance program.

Medical records are maintained for each WM with occupational exposure in accordance with 29 CFR OSHA 1910.1020.

For employees:

1. OU Health Employee Health clinic is responsible for the maintenance of the required medical records.
2. These confidential records are kept electronically for at least the duration of the employment plus 30 years.
3. Employee medical records are provided upon request of the employee or anyone who has written consent within 15 working days. Such requests should be sent to the OU Health Employee Health clinic.

For students:

1. OUHSC/OU Tulsa Student Health clinic is responsible for the maintenance of the required medical records.
2. All vaccination, titer, or declination information is to be maintained and updated within the Complio Immunization Compliance program.

Disposable Sharps:

1. Contaminated sharps shall be immediately discarded in containers that are puncture-resistant, sealable, leakproof, and adequately labeled as sharps.
2. Each dental unit is supplied with a sharps container. They should be kept in an upright position and checked periodically to prevent overfill. 
3. Once full, clinic staff are responsible for securing the lid, transporting it to the Biohazard Room, located on the first floor, and placing it into a shipping container for weekly biohazard pick up.

Non-Sharps Regulated Waste:

1. Other regulated waste (saturated gauze, extracted teeth) should be placed in a biohazard container located in each clinic. The containers are labeled Biohazard Trash Only, are closable, and are constructed to contain all contents.
2. Do not place red bags in the regular trash.
3. Red bag trash is removed, sealed, transported to the Biohazard Room located on the first floor, and placed in a shipping container for weekly biohazard pick up.
4. Surgical suction, containing liquid biohazardous waste, is disposed of in a container that is labeled Biohazard Trash Only

Non-regulated Waste:

1. Waste generated during the procedure that is not regulated (e.g., air/water syringe, patient napkins) is placed in plastic bags, sealed, and disposed of in regular trash.

Faculty, supervising provider, clinic director, or Director of Compliance will decide if the incident is, in fact, an exposure before initiating the post-exposure procedures. Determination will be made by using the BBP Exposure Management and Treatment flowchart.

If a WM sustains an exposure incident, (such as a stick with a contaminated needle, a cut by a scalpel or dental wire, or a splash of potentially infectious material in the eye, mouth, mucous membrane, or non-intact skin), the exposed person should immediately proceed with BBP exposure treatment depending on if the source is known or unknown. 

1. Treat the exposure site.
   1. Without squeezing to cause blood flow, use soap and water to wash areas of potentially infectious fluids as soon as possible after exposure.
   2. Flush exposed mucous membranes with water for 15 minutes.
   3. Flush exposed eyes at an eyewash station with water or saline solution for 15 minutes.
2. Immediately report exposure to faculty, clinic manager, and then to the COD Office of Compliance.
   1. Contact the Director of Compliance (DOC) at 405-271-3083 or
   2. Contact Compliance Coordinator at 405-271-7744 ext. 46876.
3. If the source patient is known:
   • Do not let them leave the clinic. The COD Office of Compliance will speak with the patient to obtain consent for infectious disease testing.
   • If the patient has already left the clinic, contact them to inquire if they will return for infectious disease testing.
   1. Documentation will be provided to source patients who consent to have labs drawn. Source patients should be escorted to the lab for testing.
   2. Source patient’s labs must be drawn within 1 – 2 hours of exposure for best results and treatment but no more than 24 hours after exposure.
4. WM and the Office of Compliance will document exposure on the required forms.

Employees:

1. OUHSC:
   Follow up with OU Health Employee Health the next business day. No Appointment is necessary.
   711 Stanton L. Young Blvd., Suite 400
   Oklahoma City, OK 73104
   405-271-3959
2. OU Tulsa:
   Visit Access Medical for Bloodborne Pathogen Exposure from a known source.
3. Externship or After-hours: If unable to report to a designated site listed above, visit the nearest hospital emergency room for Bloodborne Pathogen Exposure from a known source.

Students:

1. OUHSC:
   OUHSC Student Health Clinic
   900 NE 10^th Street
   Oklahoma City, OK 73104
   405-271-9675
2. OU Tulsa:
   OU Tulsa Student Health Clinic
   4502 E. 41^st Street, Suite 1C76
   Tulsa, OK 74135
   918-660-3102
3. Externship or After-hours: If unable to report to a designated site listed above, visit the nearest hospital emergency room for Bloodborne Pathogen Exposure from a known source.

Remote sites (Ardmore, Bartlesville, or Weatherford): Refer to the site-specific Exposure Control Plan.

The COD Office of Compliance will provide more instructions on how to continue with testing and medical care. Required source patient labs, for the determination of infectious disease status, will be provided at no cost to the source patient or WM.

Tests performed on source patients are:

• 30–40-minute rapid HIV 
• Hepatitis B Surface Antigen with Reflex Confirmation
• Hepatitis C Antibody with Reflex to Quantitative
• HIV 1/2 Antigen/Antibody, 4^th Generation with Reflex

Results of the source patient’s testing shall be made available to the exposed WM and the proper OU Health Employee Health Clinic or OUHSC/OU Tulsa Student Health Clinic. WM shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source patient.

• Redaction of source patient’s PHI is preferred before disclosure of results.

Source patient’s labs will be drawn at:

1. 1. OUHSC:
      OU Health Physicians Lab
      825 NE 10^th Street, 1^st Floor
      Oklahoma City, OK 73104
      405.271.6161
      Hours: 7:30 am – 5:00 pm, Monday – Friday

1. 2. OU Tulsa Students:
      OU Health – Schusterman
      4444 E. 41st St.
      Tulsa, OK 74135

1. Treat the exposure site.
   1. Without squeezing to cause blood flow, use soap and water to wash areas of potentially infectious fluids as soon as possible after exposure.
   2. Flush exposed mucous membranes with water for 15 minutes.
   3. Flush exposed eyes at an eyewash station with water or saline solution for 15 minutes.

2. Immediately report exposure to faculty, clinic manager, and then to the COD Office of Compliance.
   1. Contact the Director of Compliance (DOC) at 405-271-3083 or
   2. Contact Compliance Coordinator at 405-271-7744 ext. 46876.

3. If the source patient is unknown, WM and the Office of Compliance will document exposure on the required forms. 

Employees:

1. 1. 1. OUHSC:
         OU Health Emergency Room for a Bloodborne Pathogen Exposure from an unknown source.
      2. OU Tulsa:
         Access Medical for a Bloodborne Pathogen Exposure from an unknown source.
      3. Externship or After-hours: If unable to report to a designated site listed above, visit the nearest hospital emergency room for Bloodborne Pathogen Exposure from an unknown source.

Students:

1. 1. 1. OUHSC:
         OUHSC Student Health
         900 NE 10^th Street
         Oklahoma City, OK 73104
         405-271-9675
      2. OU Tulsa:
         OU Tulsa Student Health
         4502 E. 41^st Street, Suite 1C76
         Tulsa, OK 74135
         918-660-3102
      3. Externship or After-hours: If unable to report to a designated site listed above, visit the nearest hospital emergency room for Bloodborne Pathogen Exposure from an unknown source.

1. Remote sites (Ardmore, Bartlesville, or Weatherford): Refer to the site-specific Exposure Control Plan.

1. Following an exposure incident, a confidential examination and follow-up shall be made available to the WM to address such infectious diseases as HBV, HCV, and HIV. This shall include confidential post-exposure prophylaxis and counseling following the current CDC protocol.
2. The healthcare professional providing treatment must forward a written opinion (as outlined in the OSHA regulation) to the WM and the appropriate OU Health Employee Health clinic, OUHSC/OU Tulsa Student Health clinic, or for satellite locations, the COD Director of Compliance, and maintain a copy on file.
3. Additional information regarding the OUHSC/OU-Tulsa policies and procedures for Hepatitis B vaccination and post-exposure follow-up may be found in the OUHSC/OU-Tulsa Infectious Diseases Policy.
4. If the source patient’s HIV test is positive, prophylactic medications are available in the inpatient pharmacy.
5. If the source patient's results are positive or if the source patient is unknown, the WM should undergo periodic laboratory testing.
   1. Initial baseline test
   2. Six weeks
   3. Three months
   4. Six months

• OU Health Employee Health or OUHSC/OU Tulsa Student Health will manage the post-exposure evaluation and ensure the WM receives necessary care throughout the process.

6. If the source patient’s HIV test is negative, there is no further testing or follow-up needed.

Procedures for evaluating circumstances surrounding exposure incidents:

1. Once the incident report is received by the COD Office of Compliance, a review of the circumstances of all exposure incidents will be completed to determine the following:
   1. Engineering controls were in use at the time.
   2. A description of the device being used (including type and brand).
   3. PPE or clothing that was used at the time of the exposure incident (e.g., gloves, face shields, safety glasses, etc.).
   4. Location of the incident.
   5. The procedure being performed when the incident occurred.
   6. WM’s training.
2. The COD Office of Compliance will record the percutaneous injuries from contaminated sharps in the sharps injury log.
3. If revisions to the ECP are necessary, the Director of Compliance will ensure proper changes are made such as safer devices, adding job functions to the exposure determination section, procedural changes, etc.

To ensure that workforce member's concerns regarding needle sticks and other sharp injuries are addressed; the EHSO asks that they complete a Safer Needle Device Questionnaire annually.

OUHSC intends to adhere to current guidelines established by the CDC for preventing the transmission of tuberculosis (TB) in healthcare facilities. This will be accomplished through the OUHSC Tuberculosis Infection Control Program, which shall incorporate the fundamental elements identified in the CDC guidelines, and which shall comply with local, state, and federal law. Adherence to the procedures outlined in this infection control program should greatly reduce the risk to people in these settings. The College of Dentistry complies with the OUHSC Infections Disease Policy and Program found at HSC/OU-Tulsa Infectious Disease Policy (ouhsc.edu)

1. All workforce members at the College of Dentistry must participate in the TB surveillance program during onboarding, regardless of their participation in patient care. Employees involved in patient care will complete an annual TB screening questionnaire after their first year of service. Employee immunization records are maintained by the OU Health Employee Health Clinic. The Director of Compliance has access to the COD database.
2. The Respiratory Protection Program is available for workforce members who can potentially be exposed to TB or any other respiratory pathogens requiring an N95 respirator for treatment. The EHSO will fit-test students who want to be fit-tested. The OU Health Employee Health Clinic will fit-test any employee who wants to be fit-tested.

Patients with a medical history or symptoms suggestive of active TB should be referred promptly to the local city or County Health Department for medical evaluation of possible infectiousness.  Such patients should not remain in the dental care facility longer than required to arrange a referral.  While in the dental care facility, they should wear surgical masks and be instructed to cover their mouths and noses when coughing or sneezing. 

Patients suspected or confirmed to have active TB should be considered infective. Those patients will not be treated at the College of Dentistry until cleared as no longer contagious by a physician. Elective dental treatment should be deferred until a physician confirms that the patient does not have infectious TB.  

Patients with a persistent cough should be asked the following questions before seating in the clinic area:

1. Have you had a cough for more than three weeks?
2. Do you currently have a cough of any duration, plus one of these symptoms: cough up blood, weight loss, night sweats, or fever?

If the patient responds “yes” to any of the above questions the following must occur:

1. Give the patient a surgical mask and ask them to keep it on.
2. Refer them promptly to the local city or County Health Department for medical evaluation.
3. Reschedule the patient for a time when they are not infectious or medically cleared of active TB.