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Linda Cannon – Regulatory Compliance Specialist: COVID-19 “Confirmation” on Exposure

Staff of MSDS wish you to Stay Safe, De-Stress and Stay Active! 
Linda, Anee, Saba, Ifra, Chelsie and Patrick (no photo)
MSDS views all of our Dental Clients as Healthcare Providers!  We Thank all of you for your Outstanding work and all that you do!!

We have shown you how to screen Patients and Staff.  This Newsletter is all about Confirmation and Exposure.

Apr 29, 2020 

At Governor Northam’s daily briefing today, VDA President Dr. Elizabeth Reynolds discussed what Virginia dentists are doing to safely resume seeing patients after the Governor’s Executive Order is lifted at the end of the month. Video of the press conference is available here. 

Dr. Reynolds walked through measures that patients can expect at dental offices to keep them safe as they resume treatment that has been postponed, and encouraged them to reach out with confidence to their oral healthcare provider to schedule their next appointment. 

She also thanked the Governor for his Executive Order 60, signed earlier this week, that offers liability protections for healthcare providers, including dentists, acting in good faith during this emergency.

Governor Northam recognized the VDA for its engagement throughout the crisis and for its detailed interim guidelines, issued earlier this week, for dentists as they re-open their practices.

The Governor’s Order of Public Health Emergency 2, which related to the postponement of elective procedures, expires at 11:59 p.m. on Thursday April 30. 

So You’ve seen a Patient that was Positive for Covid-19.  He’s been Admitted the the Hospital. Should you be Worried?  Let’s Find out!

** The highest risk exposure category that applies to each person should be used to guide monitoring and work restrictions.

Note:  While respirators confer a higher level of protection than facemasks and are recommended when caring for patients with COVID-19, facemasks still confer some level of protection to HCP, which was factored into our assessment of risk.         

Epidemiologic Risk Factors
Exp. Cat.      Recommended Monitoring for COVID-19 (until 14 days after last potential exposure)Work Restrictions for Asymptomatic HCP

Prolonged close contact with a patient with COVID-19 (beginning 48 hours before symptom onset) who was wearing a cloth face covering or facemask (i.e., source control)

HCP PPE: NoneMedActiveExclude from work for 14 days after last exposure
HCP PPE: Not wearing a facemask or respiratorMedActiveExclude from work for 14 days after last exposure
HCP PPE: Not wearing eye protectionLowSelf with delegated supervisionNone
HCP PPE: Not wearing gown or gloves LowSelf with delegated supervisionNone
HCP PPE: Wearing all recommended PPE (except wearing a facemask instead of a respirator)LowSelf with delegated supervisionNone

Prolonged close contact with a patient with COVID-19 (beginning 48 hours before symptom onset) who was not wearing a cloth face covering or facemask (i.e., no source control)
HCP PPE: NoneHighActiveExclude from work for 14 days after last exposure
HCP PPE: Not wearing a facemask or respiratorHighActiveExclude from work for 14 days after last exposure
HCP PPE: Not wearing eye protectionbMedActiveExclude from work for 14 days after last exposure
HCP PPE: Not wearing gown or glovesa,bLowSelf with delegated supervisionNone

HCP PPE: Wearing all recommended PPE (except wearing a facemask instead of a respirator)b
LowSelf with delegated supervisionNone
HCP=healthcare personnel; PPE=personal protective equipment
a. The risk category for these rows would be elevated by one level if HCP had extensive body contact with the patients (e.g., rolling the patient).

b. The risk category for these rows would be elevated by one level if HCP performed or were present for a procedure likely to generate higher concentrations of respiratory secretions or aerosols (e.g., cardiopulmonary resuscitation, intubation, extubation, bronchoscopy, nebulizer therapy, sputum induction). For example, HCP who were wearing a gown, gloves, eye protection and a facemask (instead of a respirator) during an aerosol generating procedure would be considered to have a medium-risk exposure.

Additional Scenarios:

  • Refer to the footnotes above for scenarios that would elevate the risk level for exposed HCP. For example, HCP who were wearing a gown, gloves, eye protection, and a facemask (instead of a respirator) during an aerosol generating procedure would be considered to have a medium-risk exposure.
  • Proper adherence to currently recommended infection control practices, including all recommended PPE, should protect HCP having prolonged close contact with patients with COVID-19. However, to account for any inconsistencies in use or adherence that could result in unrecognized exposures, HCP should still perform self-monitoring with delegated supervision.
  • HCP not using all recommended PPE who have only brief interactions with a patient regardless of whether patient was wearing a cloth face covering or facemask are considered low-risk. Examples of brief interactions include:  brief conversation at a triage desk; briefly entering a patient room but not having direct contact with the patient or the patient’s  secretions/excretions; entering the patient room immediately after the patient was discharged.
  • HCP who walk by a patient or who have no direct contact with the patient or their secretions/excretions and no entry into the patient room are considered to have no identifiable risk.

What’s New – From CDC and the Dental Settings
Revisions were made on April 27, 2020

  • To address asymptomatic and pre-symptomatic transmission, implement source control (require facemasks or cloth face coverings) for everyone entering the dental setting (dental healthcare personnel [DHCP][ 1 ] and patients), regardless of whether they have COVID-19 symptoms.
  • Actively screen everyone on the spot for fever and symptoms of COVID-19 before they enter the dental setting.
  • Actively screen DHCP on the spot for fever and symptoms before every shift.

 FAQs on Shortages of Surgical Masks and Gowns

From the FDA!

This is packed full of information on what can use during shortages.  Keep your order in, but there are other options.  

I have asked a manufacturer to design me a Face Shield and purchasing 200 by Air –  They wrap around your face and past your ears to protect you if you don’t have the respirators.  The first one shows you that it can be loosened to add a visor to help with your loupes.  The second one I asked them to tighten it all the way.  Male docs, you can take a bandana and make it in to a skull cap (great videos on YouTube.  The rest of us, you can put the Bouffant hair covers or wear a bandana also.  

They also don’t rub your forehead, or leave marks or bruises.  And you can feel comfortable to wear a regular mask if you don’t have any respirators.  See Below.

??  Need Emergency PPE:

What’s New – From OSHA and NIOSH Decontamination of Respirators. 
April 24, 2020
FROM:   PATRICK J. KAPUST, Acting Director
Directorate of Enforcement Program
Due to the impact on workplace conditions caused by limited supplies of FFRs, employers should reassess their engineering controls, work practices, and administrative controls to identify any changes they can make to decrease the need for respirators.

If respiratory protection must be used, and acceptable alternatives are not available for use in accordance with OSHA’s previous COVID-19 enforcement memoranda, NIOSH has identified limited available research that suggests the following methods offer the most promise for decontaminating FFRs:Vaporous hydrogen peroxide;[9]
Ultraviolet germicidal irradiation; and/or

Moist heat (e.g., using water heated in an oven).
If such methods are not available, the above-referenced NIOSH-evaluated research showed the following methods could also be suitable decontamination options:
Microwave-generated steam; and/or
Liquid hydrogen peroxide.

Based on the above-referenced NIOSH-evaluated research, employers should not use the following methods unless objective data that sufficiently demonstrate the safety and effectiveness of such methods become available:

– Autoclaving;
– Dry heat;
– Isopropyl alcohol;
– Soap;
– Dry microwave irradiation;
– Chlorine bleach; and/or
– Disinfectant wipes, regardless of impregnation (i.e., chemical saturation); and/or
– Ethylene oxide (EtO).[10]

The NIOSH-evaluated research provides justification for each method evaluated.

Fit Testing of NIOSH Respirators: 

On March 14, the Occupational Safety and Health Administration issued Temporary Enforcement Guidance – Healthcare Respiratory Protection Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak. Annual fit testing of N95 respirators is being temporarily suspended to preserve and prioritize the supply

*** No Fans can be used in the Operatories  

Portable fans should NOT be used in the following situations:

*In high-risk areas including operating rooms, critical care units

*In rooms where a patient is on airborne precautions 

*In rooms where a patient is on droplet or contact precautions, for example, Clostridium difficile, MRSA, norovirus

*In rooms with directed airflow e.g. positive or negative pressure rooms

*In areas where sterile supplies are stored or where medical device reprocessing occurs, for example, hospital sterile services department, endoscopy unit

Return to Work Criteria for HCP with Confirmed or Suspected COVID-19

Use the Test-based strategy as the preferred method for determining when HCP may return to work in healthcare settings:

  1. Test-based strategy. Exclude from work until
  • Resolution of fever without the use of fever-reducing medications and
  • Improvement in respiratory symptoms (e.g., cough, shortness of breath), and
  • Negative results of an FDA Emergency Use Authorized molecular assay for COVID-19 from at least two consecutive nasopharyngeal swab specimens collected ≥24 hours apart (total of two negative specimens) [1]. See Interim Guidelines for Collecting, Handling, and Testing Clinical Specimens for 2019 Novel Coronavirus (2019-nCoV).

    If the Test-based strategy cannot be used, the Non-test-based strategy may be used for determining when HCP may return to work in healthcare settings:
  1. Non-test-based strategy. Exclude from work until
  • At least 3 days (72 hours) have passed since recovery defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath); and,
  • At least 7 days have passed since symptoms first appeared

HCP with laboratory-confirmed COVID-19 who have not had any symptoms should be excluded from work until 10 days have passed since the date of their first positive COVID-19 viral test assuming they have not subsequently developed symptoms since their positive test.
If HCP had COVID-19 ruled out and have an alternate diagnosis (e.g., tested positive for influenza), criteria for return to work should be based on that diagnosis.
Return to Work Practices and Work Restrictions

After returning to work, HCP should:

  • Wear a facemask for source control at all times while in the healthcare facility until all symptoms are completely resolved or until 14 days after illness onset, whichever is longer. A facemask instead of a cloth face covering should be used by these HCP for source control during this time period while in the facility. After this time period, these HCP should revert to their facility policy regarding universal source control during the pandemic.
    • A facemask for source control does not replace the need to wear an N95 or higher-level respirator (or other recommended PPE) when indicated, including when caring for patients with suspected or confirmed COVID-19.
    • Of note, N95 or other respirators with an exhaust valve might not provide source control.
  • Be restricted from contact with severely immunocompromised patients (e.g., transplant, hematology-oncology) until 14 days after illness onset
  • Self-monitor for symptoms, and seek re-evaluation from occupational health if respiratory symptoms recur or worsen

Organizing your computer for MSDS:

  • Make a folder on your desktop named MSDS.
  • Double click the folder.
    • Create Folders for each category. OSHA-BBP, OSHA Safety Classes, HIPAA, Medical Emergency, BLS-CPR, etc.
  • In each folder, for example, HIPAA:
    • You’ll have the Business Associate Agreement, Patient Consent Form, Office’s Privacy Practice, etc.    
We love our Clients
 OSHA-BBP Exposure Control Plan.
  • Mandatory by Federal OSHA-BBP
  • Required to be Personalized
  • Reviewed Annually by all office staff involved in OPIM. (Other Potentially Infectious Materials)
This manual is also called: The OSHA manual, The Exposure Control Plan or The Bloodborne Pathogen manual.  

If you want MSDS to help you with your Personalized manual.  The cost for non clients is $450.00.  Cost for Clients is $250.00 this gives you not only a personalized manual in binder form, but also in PDF which is the format the Inspectors will want you to have.  Best to know that we will not have you answer incorrectly vs. you writing your own manual and the manual is incorrect.  MSDS can boast that our manual has never been given anything less than an A+ from an OSHA inspector.  

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Linda L. Cannon
Director of Safety Compliance

Phone: 1-757-718-1515
Toll Free: 1-800-483-0223

Email: [email protected]

MSDS' best practices website is not a standard or regulation, and it creates no legal obligations, nor does it change any existing OSHA or other government standard or regulation. The guide is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace.