A new dental directive, No. 2020-09c and a Health and Safety Plan (Exhibit B), went into effect at midnight. There is a lot more recommending instead of requiring. There is more explanation of rationale for certain requirements and additional criteria/restrictions referred to in Heath Orders C19-08b, C19-08c and C19-07e.
Exhibit B is a 2-page checklist that you will have to print and post next to your existing Health and Safety plan. This is much easier than writing a Health and Safety Plan without a template. However, there are more things to do and comply with during this difficult time.
The new directive has a few significant changes, additions and clarifications. There are now 9 requirement categories:
1. SIGNAGE AND EDUCATION
2. GENERAL SCREENING OF PERSONNEL AND PATIENTS OR CLIENTS
3. FACE COVERINGS AND RELATED PPE
4. PHYSICAL DISTANCING
5. HAND HYGIENE
6. RISK CATEGORIZATION, PROTECTIVE ACTIONS, AND PATIENT OR CLIENT
TESTING FOR SARS-CoV-2 (RT-PCR TESTING)
7. REPORTING AND COOPERATION REQUIREMENTS REGARDING SARS-CoV-2
9. OTHER REQUIREMENTS
Please read the entire directive. There are clarifications and links to new resources, but the main changes are to requirements 6,8, and 9.
Requirement 6 “strongly recommends” and states the reasoning for testing but does not require testing, though does mandate providing educational materials to patients instructing them on how to avoid infection between visits. It strongly recommends reducing aerosol generating procedures and recommends HVE and rubber dam or other engineering controls that will reduce aerosols. It mandates when to don new PPE between patients.
Requirement 8 makes several cleaning and disinfecting recommendations and provides links to CDC guidelines. The CDC recommends letting aerosols dissipate before doing the final surface cleaning. The time required to wait will depend on the engineering protocols you have implemented.
Requirement 9 is a catch-all for what didn’t fit into the other categories, including the removal of reading materials and other shared items from waiting rooms, but there is nothing surprising.
The directive is less prescriptive and does not prevent any emergency, necessary or essential treatment and, in fact, by referral to Health Order C19-08b, clarifies that it is the provider’s sole professional judgment to determine whether a particular appointment or procedure is Essential. However, it also stresses that the intent of 19-08b is that non-essential care be postponed whenever possible to help prevent transmission of COVID-19 to the extent possible.
We want to thank our healthcare partners at the Department of Public Health, including our colleague dentists within DPH who struggled with the same concerns as private practitioners, for working with us to improve this directive so that we can get back to taking care of our patients, many of whom are now in dire need of oral health interventions.
As always, be safe and stay well.