#207 Infection Control Bloopers, Breaches and Uh-Ohs!

Infection control breaches can lead to serious consequences including disciplinary action or lawsuits. In this episode, the Divas share actual cases in dental practices that involved regulatory action. Leverage these lessons learned to protect your patients, your practice, and your license.

Resources:

• CDC Guidelines for Infection Control in Dental Health Care Settings - 2003  https://www.cdc.gov/mmwr/pdf/rr/rr5217.pdf
• CDC Summary of Infection Prevention Practices in Dental Settings - 2016   https://www.cdc.gov/dental-infection-control/hcp/index.html
• OSHA Bloodborne Pathogens Standard  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030 

                                                 https://www.thecompliancedivas.com

Transcript

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SPEAKER_01 0:05

Welcome. I'm Leslie Cannum. I'm Mary Gavoni. I'm Linda Harvey.

SPEAKER_03 0:10

I'm Olivia Wan and together we are the Compliance Divas.

SPEAKER_00 0:14

Welcome to the Compliance Divas podcast. This is Linda Harvey, and I'm particularly excited about being your moderator today because the Divas is going to talk about infection control breaches, bloopers, and other uh-ohs. As the compliance divas, we bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to our podcast through your favorite podcast channel or on our website at thecompliancedivas.com. Any resources that we mentioned today will be found on the Compliance Divas website. And we always invite you to submit questions to support at compliancedivas.com. And don't forget to scroll down and leave us a note or review at the end of the podcast today. We know that infection control breaches can lead to serious consequences, including disciplinary action, lawsuits, and injuries to patients. Incidents can range from cross-contamination risk, sloppy sterilization protocols, to patient infections, or implant failures, just to name a few. So maintaining strict adherence to known infection control producols and the manufacturer's instructions for use is essential. I'd like to ask our diva Mary to kick us off. And Mary, if you could tell us about a case you or a project you've worked on involving poor infection control.

SPEAKER_02 1:44

Sure, Linda. I've got several. I'll start off with my signature infection control do not do story. And it really reinforces the importance of not only providing training to employees, especially those that may not have experience in dentistry prior to coming to the office, but also making sure that people really understand and can demonstrate what they learned in the training. So I was in a practice a number of years ago where the packaging that they were using for their instruments was nyclave or nylon tubing. And so they would cut it to length and then heat seal the end of the packages and then tape them with autoclave tape. So they had a new dental assistant who came from outside of dentistry. She's now the sterilization assistant, and she didn't really remember a lot or comprehend a lot from her training. But what she said she remembered was don't put the instruments away from the sterilizer or the sterilization area until you see the black lines on the tape. So she fumbled with the sterilizer, couldn't get the sterilizer working. So instead of taking those packaged instruments and waiting and telling someone, what she did was get out a Sharpie and a ruler, and she traced over where the black lines would appear on the autoclave tape and then put them away. And so it had been a couple of days from the time she had been doing it until I got there for training. And apparently people on the team weren't really paying that close of attention that they should have noticed that something wasn't right. But that's a classic story of not making sure that people are comprehending their training and someone maybe mentoring them while they're doing these procedures and watching them while they're doing these procedures as a new employee. In another situation, I was called by the Board of Dentistry in a state where there was a complaint from a patient of really unsanitary conditions. And so I went in to visit the practice, and it I can't believe patients would even go there for services because it was dirty and not only in the reception area. So you walk in the door and it's dirty, you walk into the clinical area, and it was dirty, like dusty, and and just not good. And the countertop and the sterilization area had delaminated, so there was bare wood exposed, and it it just was a nightmare. So my advice to the practice was number one, you I'm gonna give you a couple of days to clean this up, really clean it up, and then we're going to work going forward, trying to get things set up the way that they need to be. And I think it was a real wake-up call for the practice. And I had a heart-to-heart with the doctor and the team. It's like you need to understand what this looks like to your patients. And I think we all, especially after COVID, need to be cognizant of that. How does our practice look aseptic? Are we following aseptic protocols? Because patients are observing those kinds of things. So this was a success story in that the practice got um up to speed, and and the doctor was very grateful after the fact that just an older doctor who just kind of let things go and and was feeling good about how things ended up and then got out of his disciplinary track with the dental board.

SPEAKER_00 5:30

Mary, those are two amazing stories. I well remember your signature story, and I love it every time you tell it because it's a reminder that sometimes new team members just don't know what they don't know. And we think we're communicating effectively with them when in fact we really haven't hit the mark. And also brings to mind your second story, the fact that routine cleaning is everybody's job. We're part of the team. Even when a practice has an outside cleaning service, we're responsible for making sure that everything within our operatory is still clean and tidy. And if the base of your chair is dirty or there's dust along the um arm of your light handle, then you should take the responsibility to clean that up because you never know what patients are seeing, and you'd get you get judged. And these days everyone is so worried about their social media reviews that you know certainly that's going to bring on a lot of negativity about a practice and dissuade new patients from coming. So thanks for sharing those. Olivia, I'd like to turn to you and ask you to please to share a case with us that you've worked on where there was poor infection control that resulted in a dental board complaint or legal action.

SPEAKER_03 6:41

One of the cases was a board complaint, similar to what you experienced, Mary. There were unsanitary conditions and surface disinfection was not being performed properly. And if I remember correctly, it seems like they were using pine sole to disinfect. They were not using hospital-level disinfectants. And among other things, there were so many things that had to be revised and tweaked. And part of their discipline with the board was to complete X amount of hours of infection control training and then to submit to monitoring. So we had quite a bit of changes to incorporate, and it was painful at first because they were having to do this punitively. But once we worked through the changes, they could readily agree that it was for the best for their safety as well as those of their patients. On another case, uh the dentist was disciplined for reusing a disposable item. And I was really surprised because the consent order stated that what the dentists had done was they made it sound very egregious, of course, but they referred to the dentist as being incompetent. And so even though they were disinfecting it, so to speak, the item was made to be one-time use and dispose of it. So you can see the severity of the discipline is not worth trying to save a few bucks or trying to reuse something. So had several with the issue of disposable items. And then this could relate to infection control, where assistants are not functioning within their scope of duties, and that resulted in board discipline. Now, thinking back of my own inspections when we do mock assessments, one of the most I don't know if I would say it's the most egregious audit that I did, but there was mouse droppings in the clinical cabinet drawers where rodents were just running the place, and there was mouse droppings on the pouches and two by two gauze and so forth. So, you know, it's so important to take a fresh approach. And I I want to mention that, you know, all of the divas offer this type of service. All of us provide these assessments that can really help prevent something like this happening or ever escalating to the point that the board needs to get involved.

SPEAKER_00 9:14

Well, thank you for sharing that case. It certainly is an eye-opener and it brings to mind some very good points for our listeners to take back and remember regarding that in their practice as well. Now I'd like to turn to our diva Leslie. Leslie, I know that you've worked on one very interesting high-profile case in California. Would you mind sharing a bit about that, please?

SPEAKER_01 9:37

Well, Linda, this is a case that actually seems to keep going and going and going. And the lawsuits that were filed as a result of this case have still not been settled as of the date of this podcast here in 2025. So it was surrounding contaminated dental unit water at a children's dental pediatric group where there were 73 children who had infections as a result of contamination in the water and dental procedures that were performed. They had pulbotomies, and 72 children were hospitalized as a result of their infections and some very serious side effects with regards to the treatment of the infections. They had surgeries, they had uh IV antibiotics that had their own side effects. It was just an amazing amount of grief for these poor children who were between two and eight years old and their families. Everyone was affected because, of course, the parents were terrified than their children had to be hospitalized. And the siblings, as you can imagine, when they think when older brother or younger brother or sister has to be hospitalized, and parents are worried. So they became very anxious and very afraid to go to the dentist as a result of all the impact. So it didn't just impact the patients, it impacted the dental practices. They actually had to close their dental practices and so they're no longer in business. But this isn't the first time that an outbreak has occurred with regards to dental unit water. Um, initially, there was a case in 2015 in Georgia. It was in Jonesboro, where a pediatric dental clinic had uh multiple cases. I believe it was around 14 or 15 children who were infected. They discovered that it was the dental unit water that had been colonizing in what's recognized in dentistry sometimes or in plumbing as a dead leg, where the non-tubercular microbacterium was colonizing and it affected children. They also had received pulpotomies. And then we actually had another case occur. We didn't know where it was in 2023 when CDC issued an alert. They called it a health alert network or a Han alert, describing contamination in dental unit water and encouraging dentists to monitor their water and to, of course, you know, follow CDC guidelines for strategies to improve water quality. And we found out at our last ADS meeting that that actually occurred in Georgia as well. So consequently, Georgia has changed their dental board regulations. Now dental practices are required to test their dental unit water quarterly to ensure that they meet EPA drinking water quality standards for non-surgical procedures. And so it's worthwhile paying attention to what has happened over the last 10, 12 years with regards to dental unit water and where we're going with regards to what steps we can take for best practices to protect our patients and to protect the reputation of our practices. Now, I did get an opportunity to go to the dental office in Anaheim. I was selected by the state's dental director at the time. He referred me to the chief health officer in Orange County, and they asked me to go in and see what else was wrong besides the dental unit water because they had already determined that the water was colonized with this non-tubercular microbacterium. And so when I went in, I did a full board and audit and I looked at everything. I found that they had 13 failed spore tests. And if you can imagine a dental practice having 13 failed spore tests, and what do you do when you have a failed spore test? By the way, podcast number 100, episode number 100, we go through those steps. So I'm not going to go through that now. I did find that they had contamination on dental instruments and they also had compromised instrument pouches. But the point being is that the one thing that that triggered all of this was this dental unit water contamination, but it didn't stop there. It went into dental board investigations. Currently, our dental board in California is reviewing the possibility of following Georgia's steps in requiring dental offices to monitor dental unit water quality. And in 2025, we're going to see what the dental board decides to do with that. And I'd encourage our listeners to really pay attention to the outbreaks that occur so that you don't have the same situation occur in your dental office. And again, following best practices for infection control and CDC guidelines for monitoring water quality of the dental unit and then taking steps to address any problems when water quality is over safe drinking water levels.

SPEAKER_00 14:47

Thank you, Leslie. And listening to your story, several things come to mind. One is saying about you never have you don't have time to do it correct the first time, but you have time to do it again. We just have to take that extra few seconds. We're not talking about five or ten minutes, that extra few seconds sometimes to double check something or look or just make sure it's done properly. Otherwise, as you just mentioned, those poor children were hospitalized, and there was a lot of issues that happened. And I think that was a good reminder of many of those details, Leslie, because perhaps some of our listeners weren't in dentistry at the time and haven't been aware of those cases. So thank you for sharing. I have an interesting case that I'd like to share that I worked on a few years ago. And it was a small dental practice, and it was a husband and wife team, and they were shorthanded with one assistant. And I don't remember exactly how long she'd been gone. Nevertheless, there was a dental board complaint by an assistant in the practice. So I'm not sure if it was the person who was still there or the person who had left. So the attorney sent me in to do an inspection. And after just being there about an hour, I had to call the attorney, tell him things were just really horrible. A lot of things were going on, which I'll explain in a moment. I had to have the client cancel patients so we could do what I would call divas emergency infection control training. So by that I mean the doctor, the uh doctor husband, I witnessed him with gloves on, and they this was a little while ago. They were still, as I said, it was an older practice, so they were still using paper records, handling paper charts, leaving the operator with his gloves on, then leaving the operatory, going into the lab, getting something, coming back with the same pair of gloves on. So he was cross-contaminating the entire practice and bringing back germs from who knows what all he touched to the patient's mouth. And then I found that the assistant who was there, like I said, I'm not sure if she's the one that called in the complaint or not, but if she was, it was like what was that old saying, like my grandmother used to use, a pot calling the kettle black or something, you know? I mean, they're both black dark, you know, iron color. So she was reusing sterilization pouches exactly how you described me with the nyclave tubing and just adding a different piece of tape. So I came in, and first thing I did was grab all those empty pouches and throw them away. I just it just was it was just very, very concerning and alarming. So the attorney we got on the phone, we we canceled patients, we had an emergency, like I said, emergency infection control training. So it's just important to remember that details matter and ensuring that when new team members come on board with a practice, no matter how many years experience they have in other practices, they don't know every detail about your practice. And we cannot assume that they're doing it to the level of how you might want in your practice. So taking time to provide that extra training and onboarding is so very important. Well, Divas, do you have any other tips or suggestions you'd like to share? Leslie?

SPEAKER_01 17:59

Well, you know, Mary's story brings up uh I remember going into an office where the first thing I do when I walk into an office is, you know, I'm a sizing up the reception room and sizing up what kind of practice I'm walking into when it's my first visit there. And then this one practice, underneath the reception room chair where the patients are seated, I saw a bloody gauze. And I thought to myself, you know, I I can understand how that might have happened. A patient probably had a tooth extracted and been on the gauze and was probably going to make sure they understood the home care instructions by taking out the bloody gauze and that little package of gauze they give you to take home probably replaced it. And uh, since there was likely no trash can, they just tossed that bloody gauze under the chair. So, what would other patients think of that? I mean, I think of it that way, but could it be that the office is dirty and that there that there might be an infection control issue? I remember also uh hearing about the uh story of the case of Dr. Scott Harrington in Tulsa, Oklahoma, where he had uh infected a patient with hepatitis C. And when the dental board did their investigation, they found a number of other things wrong. Now, he had not conducted spore testing in more than six years. That was one area where sometimes dentists are unaware whether or not their team is actually doing that. So making sure that you are in a system of spore testing is very important in a dental office, making sure that you also are looking at other things, like in his office, they found rusted instruments that had been peeling and corroded. And when the dental board had interviewed the dental assistants in that practice, they discovered that the assistants were soaking instruments in undiluted bleach. And that was the instruments that were used on patients who had HIV. So clearly, our dental assistants in this practice didn't understand standard precautions where you treat all patients the same, you treat all blood and body fluid the same, and you use the same systems for processing your instruments, the same heat sterilization or chemical vapor or steam, whichever way is your system, it needs to be good enough for all the patients, whether they have HIV or not. And another thing that I think we discussed, maybe this on a previous podcast, uh, that during the holidays, our team members do like to, you know, get in the mood and and sort of celebrate. But bringing holiday decorations into the treatment room makes it more difficult to clean and disinfect. I've seen spider webby type of stuff along the countertop and up to the x-ray arm during Halloween. I've seen Easter type of brass on the counters and I've seen for Christmas and holiday decorations. It just makes it so much more difficult. A treatment room should be easy to clean and disinfect. There should be as little as possible that prevents that from happening. And, you know, we even when we think about the things that we normally keep in a treatment room, how little can be there so that we can really do a good job and and not miss anything. When it comes to infection control, this is also important.

SPEAKER_00 21:19

Thank you, Leslie. And I'd like to ask you if you wouldn't mind repeating the previous podcast that we had on the topic of infection control. You referenced earlier.

SPEAKER_01 21:28

I had talked about the podcast where sterilization, bloopers, what do you do if you have a failed spore test? And that was podcast number 100.

SPEAKER_00 21:37

Perfect. Thank you. But I'm going to reference our listeners back to that in case they want to even have a little bit more information to add to this. And yes, Leslie?

SPEAKER_01 21:44

And and Linda, I want to remind our listeners that our podcasts have show notes that many times there's checklists that you can print out. You know, who would have thought that an audio program would have something that you could take back to your office with you in writing? And of course, the the checklist for the spore testing is one. But we have many, many, many checklists for various different things, everything from disinfectant to everything that surrounding emergencies. And it's so important to have written policies. And we are so proud of our library of podcast show notes that people can access and use for their team training and work into their standard operating procedures.

SPEAKER_00 22:27

And thank you for reminding everybody about the show notes. That's an important feature that we do offer to make it easy for our listeners to find good information at their fingertips. Well, Divas, thank you for sharing these very eye-opening uh infection control bloopers and breaches today because we can never have enough attention to detail in the dental practice. So want to be as a reminder, the compliance divas bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. We invite you to subscribe to the Compliance Divas podcast through your favorite podcast channel or on our website, the compliancedevas.com. The resources that we mentioned today will be mentioned in the show notes and listed for you. And please don't forget to resub submit any questions that you may have to support at thecompliancedeivas.com. And don't forget to scroll down and leave us a review or a rating. We'd love to hear from you. We look forward to seeing you next time.