One area where a complaint or notification may be made about you is the area of infection control. This may include an investigation by the Department of Health and then a referral to OHO for investigation.
If a complaint is made about you in relation to infection control, the OHO will likely ask you to provide evidence of compliance with the Dental Board’s Guidelines on infection control. Your dental practice may be inspected.
The type of evidence that you will be asked to provide initially may include:
- a copy of the infection control manual used at the practice that sets out the protocols and procedures;
- evidence that you and all relevant staff have access to this manual;
- photographs that demonstrate the layout of and the equipment in the sterilisation area of the clinic; and
- copies of print-outs from the autoclave(s) demonstrating the results of all cycles over a period of time.
In 2015, NSW Health attempted to notify over 11,000 people who were considered to be at risk of a blood-borne virus as a consequence of undergoing 'invasive procedures' at a dental practice.
Investigations into the dental practice was triggered by complaints made by a patient about hygiene practices. An investigation occurred, the practice was inspected and multiple shortcomings in the infection control measures at the practice were identified. Whilst in subsequent inspections, the practitioner had had taken steps to address some of these shortcomings, the practitioner’s registration was suspended for a period until it was lifted, but conditions were placed on the practitioner’s registration. The suspension was only lifted upon finding that the practice had become 100 percent compliant with the Infection Control Guidelines.
The complaints in relation to the practice related to:
- multiple breaches of Infection Control Guidelines;
- failures on behalf of the practitioner to observe appropriate sterilisation and disinfection procedures;
- staff at the practice not being appropriately trained or supervised with regard to testing procedures for autoclaves; and
- failure of the practitioner to observe appropriate procedures for the cleaning of equipment and storage of sterile and non-sterile items.
The tribunal considered that because the conduct was found to be sufficiently serious, it needed to consider whether it was appropriate to suspend or cancel the practitioner’s registration.
There were factors in this matter which favoured cancelling or suspending the practitioner’s registration. The practitioner’s conduct posed a serious threat to public health as a result of repeated breaches of Infection Control Guidelines. Although there was no evidence any of the practitioner’s patients contracted a blood borne virus, this did not change the fact that he endangered his patients. Also, an order suspending or cancelling the practitioner’s registration would serve an educative function by reminding the profession of the critical role the Infection Control Guidelines play in protecting patients and the dangers of departing from the guidelines.
These factors were balanced against the evidence of the practitioner’s rehabilitation. Although initially the practitioner took limited steps to rectify his breaches, following his initial suspension, the practitioner went to great lengths to improve the standards at his practices. All inspections following his initial suspension noted that the practitioner’s practices were now well above the average standard of a dental practice.
In light of this, the tribunal decided not to suspend or cancel the practitioner’s registration. Instead, it was considered appropriate to issue a reprimand and impose conditions upon his registration. The practitioner was required to submit to regular inspections of his practice and establish and maintain a mentoring relationship with a senior practitioner. The tribunal elected not to impose a fine upon the practitioner.