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Public Health Releases New IPAC Checklists for Dentists

By November 28, 2017August 18th, 2022Employment Law

New IPAC Checklists for Dentists

The infection prevention and control (“IPAC”) craze has had dentists scratching their heads for quite some time wondering where to turn for answers about IPAC, Public Health Ontario (“PHO”) inspections, which of the many IPAC guidelines to follow, how to respond to inspectors, etc.  If you’re out of the loop and need to find out more about the “craze” that started last summer, see our previous IPAC blogs by clicking here.

The IPAC confusion has spurred the RCDSO to collaborate with PHO and earlier this month, PHO released new checklists for CORE Elements and Reprocessing which are specific to dental practice settings!

Inspections Going Forward

The description of the checklists on the PHO website states:

These checklists were developed to assist public health units and others during IPAC lapse investigations and can be used to conduct inspections, audits and reviews of IPAC programs in dental practice settings.

That’s helpful, right?  But it appears that an inspector who comes to your practice may be using these two checklists to assist in ensuring compliance. The language is not definitive and room is left for inspectors to use other documents.  What’s more, the checklists reference sources from the RCDSO guidelines and Dispatch articles, the Occupational Health and Safety Act, PHO documents, Provincial Infectious Diseases Advisory Committee (PIDAC) documents, the Centres for Disease Control and Prevention (CDC) documents, etc.

So, although instructive on the matter, the new checklists may not be the definitive answer dentists were waiting for about their IPAC obligations!

But, What About New Guidelines?

The RCDSO put out a news release early this month stating that they have worked closely with PHO to develop the new checklists.

The RCDSO also took the opportunity to confirm that the RCDSO has always and continues to suggest that dentists’ professional obligations include

following public health guidelines as well as the recommendations of manufacturers of sterilization and other dental office equipment to ensure patient safety at all times.

They also hint at “potential changes” to the RCDSO Guidelines but confirm that no changes are anticipated until at least the new year.

What’s interesting is that despite recommendation that dentists follow public health guidelines and manufacturer recommendations for sterilization, they also state the current RCDSO guidelines will remain in effect and that “We have had no reports of any dental office that follows the current Guidelines being closed”  which is a confusing message to send to dentists.

Right now, dentists don’t know where to turn for authoritative IPAC information. They are pulled in every direction from PIDAC to RCDSO to CDC to CDA – each of which have their own guidelines, recommendations and IPAC documents – some of which are similar but not always the same.  And with confusing and contradictory information about which document to follow for proper IPAC measures in their dental practice, no wonder there is so much head scratching going on.

Although not the definitive answer dentists were waiting for, the new checklists are certainly instructive and a step in the right direction. But it is my hope that the PHO and RCDSO continue to collaborate to create a consolidated guideline document for dental practices that will help dentists to easily access one authoritative document and then feel safe and at ease knowing that they are conducting their IPAC using the authoritative guideline on the matter.

And in the Meantime?

In the meantime, dentists should be familiar with both PIDAC and RCDSO guidelines on IPAC.  If you are a dentist in Ontario you should absolutely use the new checklists to conduct an internal inspection and to see if your office would comply if an inspector walked into your dental practice today! And be sure to familiarize yourself with the other documents cited in the checklists!

Please note that the information provided herein should not be considered legal advice and is provided for informational and educational purposes only. If you need advice about IPAC at your dental practice, please contact DMC.  We are your legal dental team.

The Content of this post is provided for informational purposes only. It is not intended to be legal, financial, tax, or other professional advice of any kind. You are advised to contact DMC (or other counsel) to seek specific legal advice concerning your individual situation.