The University of Southern California (the "University") School of Dentistry (the "School") recognizes that bloodborne pathogens pose serious health concerns to our patients, faculty, students and staff. The School is committed to educational programs and institutional policies that will respond appropriately and effectively to these significant health risks.

In order to respond to the various issues surrounding bloodborne pathogens with sensitivity, flexibility, compassion, and with the best current medical, scientific and legal information available, it is the policy of the School to review, evaluate and respond on an individual case-by-case basis to any instance of infected personnel who participate in academic or clinical programs. The School will address the subject of bloodborne pathogens with overall concern for the rights and interests of patients, faculty, students and staff.

All actions taken pursuant to this Policy shall be taken in conjunction with University policies and procedures, and current California and federal law, applicable to the individual involved. For example, actions taken pursuant to this Policy in regard to School employees shall be taken in conjunction with University policies and procedures, and current California and federal law, applicable to employees.

This policy applies to School Personnel, as defined below.

Bloodborne pathogens means pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus ("HBV") and human immunodeficiency virus ("HIV").

Exposure prone procedures means procedures which include digital palpation of a needle tip in a body cavity or the simultaneous presence of a healthcare worker's fingers and a needle or other sharp instrument or object in a poorly visualized or highly confined anatomic site. Performance of exposure prone procedures presents a recognized risk of percutaneous injury to the healthcare worker, and if such an injury occurs, the healthcare worker's blood is likely to contact the patient's body cavity, subcutaneous tissues, and/or mucous membranes.

Infected individual means any Personnel (as defined below) who is infected with a bloodborne pathogen.

Personnel means School faculty (including full-time, part-time, volunteer and visiting faculty), students (including undergraduate, graduate or post-graduate), and other staff members as determined by the School, who are involved with patient care or otherwise provide services in the clinical setting.

1. The School currently requires that all students faculty and staff who provide patient care receive the HBV vaccine or demonstrate immunity to HBV before they begin training or teaching at the School. For ethical, professional and moral reasons, it is recommended that all faculty, students and staff who provide patient care and who are training or teaching at the School undergo voluntary testing for HIV on a regular basis.

2. Personnel are required to comply with all safety and infection control precautions, including universal precautions, as set forth in the School's policy titled Guidelines for Infection Control. Personnel who willfully violate School infection control policies shall be subject to disciplinary action per School policy.

3. The School requests that Personnel who are involved in patient contact and who test positive for a bloodborne pathogen disclose this information to the Director of Safety and Facilities Management.

4. Personnel who know they are infected with a bloodborne pathogen, or who have a reasonable belief that they are infected with a bloodborne pathogen, must cease performing exposure prone procedures pending completion of the Committee's review and evaluation, as set forth below.

1. When notified that an individual is infected with a bloodborne pathogen, the Director of Safety and Facilities Management shall notify the Dean. In the case of HIV or HBV infection, within five business days of the report of infection, the Dean or his or her designee shall select a Committee ("Committee") to undertake an individual review and evaluation of the infected individual's practice at the School, the nature of the disease, the risk of transmission of the disease to others, and to recommend the circumstances, if any, that infected individual may be permitted to continue to perform exposure prone procedures or other patient care procedures at the School. The Committee review shall be on a blind basis unless the infected individual provides written consent to allow his or her identity to be revealed to the Committee.

2. For infections other than HIV or HBV, within (five) business days of the report of infection, the Dean or his or her designee in his or her discretion may convene a Committee to undertake such a review and evaluation, based on an assessment of the general nature of the infection. The Dean shall seek guidance from medical experts and legal counsel as necessary in making this determination.

3. The committee should include at least five members who do not know the identity of the infected individual, and should include experts who present a balanced perspective. The Committee should include (1) an infectious disease specialist with expertise in the epidemiology of HIV and HBV transmission (or other bloodborne pathogen at issue), (2) a faculty member with expertise in the procedures performed by the infected person, (3) a dentist, (4) a physician, (5) legal counsel, and (6) any other individuals who may be chosen for their expertise, concern for, or involvement in the activities of the School.

4. The Committee shall meet as soon as reasonably practicable, but no later than (five) business days after the Committee members have been selected.

5. The Committee should be guided by applicable California and federal laws, objective medical and scientific evidence, relevant medical, scientific and legal literature, the recommendations of the Centers for Disease Control and Prevention, the U.S. Public Health Service, The American Dental Association, the American Association of Dental Schools, other professional associations, the expressed desires and opinions, of the individual with the infection, the policies and procedures of the University, the School's commitment to the protection of both the public health and the individual's interests.

6. The Committee shall consider the individual's practice at the School, and the nature of the disease. The Committee shall evaluate whether a direct threat to the health or safety of others is present by considering the following: (1) the nature of the risk (how the disease is transmitted), (2) the duration of the risk (how long is the carrier infectious), (3) the severity of the risk (what is the potential harm to third parties), and (4) the probabilities the disease will be transmitted and will cause varying degrees of harm. The Committee shall then evaluate reasonable accommodations to reduce the risk to the health or safety of others, and shall recommend the circumstances, if any, that the infected individual may be permitted to continue to perform exposure prone procedures and other patient care procedures at the School.

7. The School will attempt to reasonably accommodate infected individuals who pose a direct threat to the health or safety of others, so that they may continue their activities at the School. In the case of students, this may mean that the student will continue his or her clinical practice at a location other than the School, where the individual will not pose a direct threat to the health or safety of others, and in this way complete his or her degree objective. In the case of faculty, this may mean that certain activities which pose a direct threat to the health or safety of others may be precluded, and other reasonable accommodations made. In the case of staff, certain job duties or assignments may be altered, and other assignments given in their place. If a direct threat to the health or safety of others cannot be eliminated with reasonable accommodations, career or educational opportunities external to the School may be proposed.

8. The committee shall issue its evaluation and recommendations to the Dean in writing, within 10 business days of its first meeting. The Dean shall consider the Committee's evaluation and recommendations, and shall issue a determination, either approving or modifying the Committee's recommendations.

9. Within (five) business days after the Committee has completed its written evaluation and recommendations, the Dean's determination will be discussed informally with the infected individual. If the infected individual challenges the dean's determination, the dean will convene a formal hearing within (five) working days. Members attending the formal hearing will be the Director of Safety and Facilities Management and other Committee members as approved jointly by the infected individual and the Dean.

10. Within five business days after the formal hearing, the infected individual may appeal the Dean's determination to the Director of Risk Management of the University.

11. No otherwise qualified individual will be prohibited from participating in any School program or activity as a result of his or her infection, unless the individual's participation in the program or activity poses a direct threat to the health or safety of others, and the threat cannot be eliminated with reasonable accommodation.

12. The School shall consult legal counsel as necessary before taking any action to alter to restrict an infected individual's activities at the School based on the individual's infection.

1. The School shall ensure that the privacy rights of all infected individuals are respected. All medical information provided to the School regarding an infected individual will be kept strictly confidential.

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