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New CDC Regulations Coming to Washington State

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In the aftermath of large and serious outbreaks in Orange County, CA and Atlanta, GA directly relating to dental unit waterlines, the Dental Quality Assurance Commission on the Washington State Department of Health has looked to create clear regulations for water safety in the dental office.

They join 32 other state dental boards requiring practices to test their waterlines regularly to ensure compliance with Centers for Disease Control (CDC) guidelines. This means, practices need to show their waterlines contain 500 CFU/mL or less of heterotrophic bacteria meeting EPA standards for safe drinking water.

ProEdge covered Washington's proposed regulations in November, 2018, but things have been rather silent since then. However, last week the dental commission in Washington approved the following regulations and has moved to put it into place in 2021.

We want to break down what it says about dental unit waterlines and answer the question, "What does this mean for my practice?"

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The NEW REGULATIONS

WAC 246-817-660 is unique in that it will not take effect until December 1st, 2021. That doesn't mean you should wait until mid-November of next year to finally start thinking about it, but it does mean you have time to get a great protocol in place that passes testing consistently.

So here's what it says:

  • A licensed dentist shall use water for nonsurgical procedures that meets United States Environmental Protection Agency regulatory standards for drinking water of five hundred or less colony-forming units or ≤500 CFUs/mL.

  • A licensed dentist shall follow dental equipment manufacturer's instructions when testing the water delivery system for acceptable water quality. If manufacturer's instructions are unavailable, a licensed dentist shall test the water delivery system for acceptable water quality quarterly. A licensed dentist shall test the water delivery system five to ten days after repair or changes in the plumbing system and again at twenty-one to twenty-eight days later.

  • Effective December 1, 2021, all water lines must be tested.

  • All water lines for each operatory or dental unit can be pooled as one single sample.
    • A pooled sample must use an equal amount of water from each water line.
    • A pooled sample can have up to ten water lines included.

  • The number of water lines pooled into one sample must be documented.

  • All water lines for each operatory or dental unit can be tested individually.

  • In the event of an unacceptable level of colony-forming units or CFUs, a licensed dentist shall take immediate remedial action. For the purposes of this section, remedial action means any action necessary to reduce the CFUs to five hundred or a lesser number currently recognized by the United States Environmental Protection Agency as acceptable for drinking water.

  • A licensed dentist shall record the water delivery system testing and maintenance either in the form of a log reflecting dates and person or persons conducting the test or maintenance or copies of reports from an independent testing entity. A licensed dentist shall maintain this documentation for a period of five years.

You can read the full list of regulations here.

What DOES THIS mean for me?

If you are a dedicated dental pro in the state of Washington (or anywhere else!), here are five key infection prevention actions for your practice.

  1. Test your waterlines to see if you are compliant. Over 31% of treated waterlines fail to meet the ≤500 CFUs/mL standard.
  2. Shock your waterlines if testing reveals failure(s).
  3. Retest to ensure your waterlines are now clean and safe.
  4. Develop a waterline maintenance protocol to help develop consistent testing procedures.
  5. Document maintenance procedures and test results. 

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6 Tips you need to succeed in waterline compliance 

We've been around the block long enough to see consistent patterns when regulations like this is adopted into the dental community. Our hope is to shed some light on a few "obstacles" that practices have run into in the past and help you steer clear of them.

  • Don't wait until the last minute to become compliant. 2020 has become stressful enough, don't pile on the stress in 2021; take care of your waterlines sooner rather than later. We've found that waterlines fail, testing take times, and developing a maintenance protocol is a team effort. The sooner you can nail down an effective maintenance protocol the better. If you wait until the last minute you may end up paying more money for a quick-fix solution. Which goes into our next point...
     
  • Don't buy into quick-fix/miracle products. We get it, when a sales rep shows you a one-and-done solution, it's very enticing. But the science doesn't support it, we have done hundreds of thousands of tests over the years and the results don't lie; shocking and treating dental unit waterlines with proven products is the most successful way to consistently pass your water test. Because of the data we developed a proven protocol that can be implemented into any practice.

  • Do your research! Not all products are created equal. We've tested dozens of products thousands of times and have found some incredible products that work really well (Liquid Ultra, ICX, and BluTube to name a few). You can see the full product review here.

  • Reach out to improve compliance. That's right, statistically those who reach out to our safe water specialists have seen higher levels of success. We care about dedicated dental pros. Our goal is to help you pass, so if you feel overwhelmed, stressed or confused, call us, our team wants to connect with you! 

  • New doesn't equal clean. We have a ton of resources on the science behind biofilm development and bacteria growth, but here's the gist. Just because you have a new or semi-new chair doesn't mean it won't instantly start growing biofilm the moment you pump water through your waterlines. The moment water is in your waterlines, you have a biofilm problem.

  • Designate an infection prevention pro. If you haven't already be sure to follow CDC guidelines in appointing an infection control coordinator. Prior to handing this off, be sure to provide the necessary training, setup a robust protocol, and purchase products that will set them up for success. 

How we can help

We get that you didn't go into dentistry to treat waterlines, but we did. It's our goal to help you succeed in compliance and patient health. So with that, here are some ways we can be a benefit to you:

  1. Complimentary consultations are a game changer. We don't charge you to talk with us, because we genuinely care about your practice. Regardless of which products you chose to use, we are more than happy to field your questions and help you develop a protocol that works for you and your office. Try it out, seriously, drop us a call and just have a conversation with us about waterlines.

  2. BluTube is a straw product that works. We get that there are other products on the market that claim some pretty bold things. But from our research a two cartridge system is simply the best way to stay compliant. You can see the science here.

  3. Training, resource, and science. Over the years we have developed a robust library of everything waterlines. Want to learn how to shock properly, or proper aseptic technique while collecting a pooled sample, or join a webinar that deep dives into the science behind dental unit waterlines. We have everything your team needs to be successful in waterline compliance and it's free! 

  4.  We get it. Waterline maintenance can be a challenge and you have a lot of other tremendously important things to do. We understand cleaning waterlines isn't why you got into dentistry and most patients won't know what you do behind the scenes. But we do and we thank you. We have partnered with thousands of dedicated dental pros and have pushed our team to learn how to meet your waterline needs and support you where we can. 

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