where it is difficult or impossible to differentiate between body fluids;
( 2) Any unfixed tissue or organ (other
than intact skin) from a human (living or
( 3) HIV-containing cell or tissue cultures,
organ cultures, and HIV- or HBV-containing culture medium or other
solutions; and blood, organs, or other tissues from experimental animals infected
with HIV or HBV.
As the CDC points out in standard precaution protocols, since it is nearly impossible to
know if OPIM contains any blood, effectively
all of these should be treated
as infectious at all times.
Human sweat is not
considered OPIM unless
a known infection
design work process controls, train employees
to use them, and supervise their use. Hand
sanitation is a typical work process control.
A critical control is the sharps injury prevention program, the controls designed to prevent
needle sticks and other percutaneous injuries.
Also crucial to the controls are personal
protective equipment (PPE). The employer is
responsible for having the proper equipment
available at all times, for training, and for
supervising the staff and physicians.
Exposure control plan
Having determined the employees who have
occupational exposure by job category, the
practice must prepare an exposure control
plan and train the employees on the plan
protocols. In many practices, the common
exposures come from bleeding, splashing,
and needle sticks, but other events may occur.
The plan should cover all anticipated
employee exposures and be broad enough
to cover unusual incidents. The plan should
include a feedback loop — all incidents
should be analyzed in light of patterns of
incidents and possible points for improvement. Employees must be trained to report all
exposures immediately, and supervisors must
be trained in proper responses. Physicians are
also subject to these protocols.
There is a significant risk of transmis-
sion of Hepatitis B pathogens during an
All employees in
the exposed categories
should be vaccinated
during their initial work
period. The vaccination
is highly effective and
need not be repeated.
should be maintained.
The opioid crisis is creating new concerns,
particularly inadvertent exposure to fentanyl,
which can be fatal. If there is any possibility
of such exposure in your practice, protocols
must be developed and staff and physicians
must be trained.
Why not just photocopy the law and pass it
out to physicians and staff? Besides being
too long, the law does not exactly read
Policy and procedure statements need to
be: (1) written in plain English, ( 2) useful for
training, ( 3) customized to your organization,
The opioid crisis is
creating new concerns,
exposure to fentanyl,
which can be fatal.