We are currently NOT taking new patients.
Updated: 2021
The mission of the Occupational Health and Safety Administration (OSHA) is to save lives, prevent injuries, and protect the health of America’s workers. As part of the Department of Labor, OSHA promotes worker safety and health in every workplace in the United States.
OSHA’S bloodborne pathogens standard protects employees who work in occupations where they are at risk of exposure to blood or other potentially infectious materials.
OSHA’s hazard communication standard protects employees who may be exposed to hazardous chemicals.
Both standards require employers to develop written documents to explain how they will implement each standard, provide training to employees, and protect the health and safety of their workers.
This publication includes an exposure control plan to meet the requirements of the OSHA bloodborne pathogens standard and a hazard communication program to meet the requirements of the hazard communication standard within Sundrop Dental Clinic.
This information is always available to employees and should be referenced as needed.
Sundrop Dental Clinic is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.”
The ECP is a key document to assist our organization in implementing and ensuring compliance with the standard, thereby protecting our employees.
Clifford Sondrup is responsible for the implementation of the ECP. Clifford Sondrup will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. He can be contacted at 8016480503
Those employees 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.
Clifford Sondrup will provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. He can be contacted at 8016480503
Clifford Sondrup will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. He can be contacted at 8016480503
Clifford Sondrup will provide training to employees on hepatitis B vaccinations, addressing safety, benefits, efficacy, methods of administration, and availability.
The hepatitis B vaccination series is available at no cost after initial employee training and within 10 days of initial assignment to all employees identified in the exposure determination section of this plan.
Vaccination is encouraged unless:
1) documentation exists that the employee has previously received the series;
2) antibody testing reveals that the employee is immune; or
3) medical evaluation shows that vaccination is contraindicated. However, if an employee declines the vaccination, the employee must sign a declination form. Employees who decline may request and obtain the vaccination at a later date at no cost. Documentation of refusal of the vaccination is kept on Sundrop Dental Clinic's internal Denial upload hub. Following the medical evaluation, a copy of the health care professional’s written opinion will be obtained and provided to the employee within 15 days of the completion of the evaluation. It will be limited to whether the employee requires the hepatitis vaccine and whether the vaccine was administered.
Universal Precautions
All employees will utilize universal precautions.
Exposure Control Plan
Employees covered by the bloodborne pathogens standard receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees can review this plan at any time during their work shifts by contacting navigation to this page, which is continuously available free of charge and immediate. Clifford Sondrup is responsible for reviewing and updating the ECP annually or more frequently if 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.
Engineering Controls and Work Practices
Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. The 6 specific engineering controls and work practice controls used are listed below:
sharps containers, needle safety devices, red-bags, rubber dams, high-volume evacuation, instrument cassettes, and mechanical instrument cleaners.
Sharps disposal containers are inspected and maintained or replaced by Clifford Sondrup at a stage that prevents overfilling. This facility identifies the need for changes in engineering controls and work practices through a review of OSHA records, employee interviews/Reporting. We evaluate new procedures and new products regularly by reviewing the literature and updating OSHA standards at this location. Both front-line workers and management officials are involved in this process in the following manner: Providing annual training on reporting processes and providing continuous record-keeping of internal concerns for all employees. Clifford Sondrup is responsible for ensuring that these recommendations are implemented. A link to this reporting process is provided below this section.
Personal Protective Equipment (PPE)
PPE is provided to our employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is provided by Clifford Sondrup on this website and during in-person training sessions.
The types of PPE available to employees are as follows:
Masks, including surgical masks and N-95 mask, Custom Earplugs upon request, Safety goggles, Surgical gowns, Faceshields, Surgical Caps upon request. All Questions regarding use, availability, and replacement of PPE can be addressed to Clifford Sondrup
All employees using PPE must observe the following precautions:
■ Wash hands immediately or as soon as feasible after removing gloves or other PPE.
■ Remove PPE after it becomes contaminated and before leaving the work area.
■ Used PPE may be disposed of in Operatory Trash Cans or in Clinic Laundry (Gowns)
■ Wear appropriate gloves when it is 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 or 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 protection when splashes, sprays, spatters, or droplets of blood or 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. The procedure for handling used PPE is as follows: Removal of PPE in the contaminating operatory. Used PPE may be disposed of in Operatory Trash Cans. Wiping reusable PPE with proper sterilizing agents with new gloves and proper technique and bundling gowns with the inside out and placing them in the Clinic laundry bag.
Housekeeping
Regulated waste is placed in containers that are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see the following section “Labels”), and closed prior to removal to prevent spillage or protrusion of contents during handling. The procedure for handling sharps disposal containers is: The container box is unlocked by Clifford Sondrup after it has been secured closed. This is done after clinic hours to prevent potential Employee exposure. The container is then taped shut and placed in a size-appropriate box which is, in turn, taped shut. The box is then labeled with appropriate sharps labels and delivered to professional sharps disposal partners.
The procedure for handling other regulated waste is: Immediate placement in red bags for immediate disposal. When the contaminating volume is estimated to produce drops of liquid the item is placed in a red bag and delivered to the external trash can.
Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms, and appropriately labeled or colorcoded. Sharps disposal containers are available at each operatory. Trays are cleaned and decontaminated as soon as feasible after visible contamination. Broken glass as in glass slabs or carpules that may be contaminated is only picked up using mechanical means, such as a brush and dustpan.
Laundry
Laundering of gowns will be performed by Clifford Sondrup at Sundrop Dental Clinic.
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.
■ wear the following PPE when handling and/or sorting contaminated laundry: Gown, Gloves, Eye protection.
Labels
The following labeling methods are used in this facility: Red bags with biohazard labels, Sharp containers with appropriate biohazard labels, appropriate labeling of Radiology equipment, Clifford Sondrup is responsible for ensuring that warning labels are affixed or red bags are used as required. Employees are to notify Clifford Sondrup with the below link if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc., without proper labels.
The following is a list of job classifications in which some employees at our establishment have occupational exposure. 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:
Dentist: Working directly on, and around patients
Dental Assistant: Working directly on, and around patients
Dental Hygienist: Working directly on, and around patients
Front Desk Staff: Working directly around patients
All Staff is therefore at risk of Exposure
Medical Records Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.”
Clifford Sondrup is responsible for the maintenance of the required medical records. These confidential records are kept in our HIPPA Compliant google drive for at least the duration of employment plus 30 years. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to Clifford Sondrup.
Should an exposure incident occur, contact Clifford Sondrup at the following number 8016480503.. Following initial first aid (clean the wound, flush eyes or another mucous membrane, etc.), the following activities will be performed:
Document the routes of exposure and how the exposure occurred through our internal HIPPA Compliant Google Form. This will generate the appropriate medical consults for both the Source and Recipient. This will also simultaneously accomplish, which is notated in the form and medical consults:
■ Identify and document the source individual (unless the employer 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 employee’s health care provider.
■ 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 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 (e.g., laws protecting confidentiality).
■ After obtaining consent, collect exposed employee’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status
■ If the employee 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 employee elects to have the baseline sample tested during this waiting period, perform testing as soon as feasible.
ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP
ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP (Name of responsible person or department) 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. (Name of responsible person or department) ensures that the health care professional evaluating an employee after an exposure incident receives the following: ■ a description of the employee’s job duties relevant to the exposure incident ■ route(s) of exposure ■ circumstances of exposure ■ if possible, results of the source individual’s blood test ■ relevant employee medical records, including vaccination status (Name of responsible person or department) provides the employee with a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation.
Clifford Sondrup 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 (O.R., E.R., patient room, etc.)
■ procedure being performed when the incident occurred
■ employee’s training
Clifford Sondrup will record all percutaneous injuries from contaminated sharps in a Sharps Post Injury documentation Form. If revisions to this ECP are necessary Clifford Sondrup will ensure that appropriate changes are made.
All employees who have occupational exposure to bloodborne pathogens receive initial and annual training conducted by Clifford Sondrup DDS.
All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. This is done through re-completion of the bloodborne pathogen module following the exposure, this includes
■ a copy and explanation of the OSHA bloodborne pathogen standard which is available perpetually and instantly
■ an explanation of our 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, and that the vaccine will be offered free of charge
■ information on the 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 13
■ 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. Training materials for this facility are available on this website under the Annual Training Tab.
Training Records Training records are completed for each employee upon completion of training. These documents will be kept for at least three years in the appropriate folder within our HIPPA Compliant google drive.
The training records include:
■ the dates of the training sessions
■ the contents or a summary of the training sessions
■ the names and job titles of all persons attending the training sessions Employee training records are provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to Clifford Sondrup
Medical Records Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.”
Clifford Sondrup is responsible for the maintenance of the required medical records. These confidential records are kept in our HIPPA Compliant google drive for at least the duration of employment plus 30 years. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to Clifford Sondrup.
An 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 Clifford Sondrup.
In addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a POST-EXPOSURE EVALUATION AND FOLLOW-UP form which contains all the elements of a Sharps Injury Log.
All incidences 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 will have any personal identifiers removed from the report.
HEPATITIS B VACCINE DECLINATION is included in the hiring documents and contains the following text:
HEPATITIS B VACCINE DECLINATION (MANDATORY) I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me. Signed: (Employee Name)________________ Date:________________
The following model Hazard Communication Program is based on the requirements of the OSHA Hazard Communications Standard, 29 CFR 1910.1200.
Sundrop Dental Clinic Policy
To ensure that information about the dangers of all hazardous chemicals used by Sundrop Dental Clinic is known by all affected employees, the following hazardous information program has been established.
Under this program, you will be informed of the contents of the OSHA Hazard Communications Standard, the hazardous properties of chemicals with which you work, safe handling procedures and measures to take to protect yourself from these chemicals.
This program applies to all work operations in our company where you may be exposed to hazardous chemicals under normal working conditions or during an emergency situation. All work units of this company will participate in the Hazard Communication Program.
Copies of the Hazard Communication Program are available continuously and instantly at this site for review by any interested employee.
Clifford Sondrup is the program coordinator, with overall responsibility for the program, including reviewing and updating this plan as necessary.
Container Labeling
Clifford Sondrup will verify that all containers received for use will be clearly labeled as to the contents, note the appropriate hazard warning, and list the manufacturer’s name and address. Clifford Sondrup will ensure that all secondary containers are labeled with either an extra copy of the original manufacturer’s label or with labels marked with the identity and the appropriate hazard warning.
For help with labeling, see Clifford Sondrup.
On the following: Sharps Containers, Red bags, we are using the appropriate manufacturer-provided labels
Clifford Sondrup will review the company labeling procedures continuously and will update labels as required.
Material Safety Data Sheets (MSDSs)
Clifford Sondrup is responsible for establishing and monitoring the company's MSDS program. He will ensure that procedures are developed to obtain the necessary MSDSs and will review incoming MSDSs for new or significant health and safety information. He will see that any new information is communicated to affected employees. The procedure below will be followed when an MSDS is not received at the time of initial shipment: The MSDS will be obtained online and be printed or secured for future use.
Copies of MSDSs for all hazardous chemicals to which employees are exposed or are potentially exposed will be kept in our internal google drive and be available for quick reference from the internal clinic dashboard. MSDSs will be readily available to all employees during each work shift as it is part of and linked to from our normal workflow. If an MSDS is not available, contact Clifford Sondrup. MSDSs will be readily available to employees in each work area using the following format: Digital and linked to on our internal dash. This is done by clicking the link that says MSDS on the clinic dashboard.
Employee Training and Information
Clifford Sondrup is responsible for the Hazard Communication Program and will ensure that all program elements are carried out. Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on the hazard communication standard and this plan before starting work. Each new employee will attend a health and safety orientation that includes the following information and training:
■ An overview of the OSHA hazard communication standard
■ The hazardous chemicals present at his/her work area
■ The physical and health risks of the hazardous chemicals
■ Symptoms of overexposure
■ How to determine the presence or release of hazardous chemicals in the work area
■ How to reduce or prevent exposure to hazardous chemicals through use of control procedures, work practices and personal protective equipment
■ Steps the company has taken to reduce or prevent exposure to hazardous chemicals
■ Procedures to follow if employees are overexposed to hazardous chemicals
■ How to read labels and MSDSs to obtain hazard information
■ Location of the MSDS file and written Hazard Communication program Prior to introducing a new chemical hazard into any section of this company, each employee in that section will be given information and training as outlined above for the new chemical hazard.
The training format will be as follows: Annual training, following initial training upon hire using a question and answer format, in addition, to clearly delineated reading modules. This will be documented digitally on our internal drive.
Hazardous Non-routine Tasks
Periodically, employees are required to perform non-routine tasks that are hazardous.
Examples of non-routine tasks are: None anticipated, this will be updated if these tasks arise
Prior to starting work on such projects, each affected employee will be given information by Clifford Sondrup about the hazardous chemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the employee should use, and steps the company is taking to reduce the hazards, including ventilation, respirators, the presence of another employee (buddy systems), and emergency procedures.
Informing Other Employers/Contractors
It is the responsibility of Clifford Sondrup to provide other employers and contractors with information about hazardous chemicals that their employees may be exposed to on a job site and suggested precautions for employees. It is the responsibility of (name of responsible person and/or position) to obtain information about hazardous chemicals used by other employers to which employees of this company may be exposed. Other employers and contractors will be provided with MSDSs for hazardous chemicals generated by this company’s operations in the following manner: (Describe company policy here) In addition to providing a copy of an MSDS to other employers, other employers will be informed of necessary precautionary measures to protect employees exposed to operations performed by this company. Also, other employers will be informed of the hazard labels used by the company. If symbolic or numerical labeling systems are 19 used, the other employees will be provided with information to understand the labels used for hazardous chemicals for which their employees may have exposure.
List of Hazardous Chemicals
A list of all known hazardous chemicals used by our employees is attached to this plan as our MSDS list. These procedures are used continuously and universally across laboratory and operatory areas, therefore we exclude these specificities. When new chemicals are received, this list is updated (including the date the chemicals were introduced) within 30 days. To ensure any new chemical is added in a timely manner, the following procedures shall be followed: The individual who orders the item is required to pursue the MSDS and addend the MSDS sheet. The periodic review of this process will be done by Clifford Sondurp. The hazardous chemical inventory is compiled and maintained by Clifford Sondrup.
Program Availability
A copy of this program will be made available, upon request, to employees and their representatives.