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OSHA Compliance

I know that dealing with all of the new governmental rules and regulations that plague the average dental office can be a bother, but this can be a major headache for the bigger that average dental office. 

 

This is the essential information that every dental office must know and utilize. It is the law! Remember that all dentists are now required to be instructed upon OSHA and Infection Control during every licensing period; however, that is not all. We are also required to implement this information. This information is widely available so let me refresh your memory.

 

Did you know that the term, “M.S.D.S” is now outdated. The new term is simply S.D.S. (Safety Data Sheet). We will all be receiving new S.D.S.'s from manufacturers of our dental products as we get our new supplies. The change comes as a result of worldwide changes made by the United Nations to create a ”Globally Harmonized System”. This is set to be phased in during the period from 2013 through 2016. You may have already noticed this change. So, to be in compliance with the new rules, we all need to update our old M.S.D.S. Manuals to reflect the new paradigm.

 

There are many new mandatory changes. The conversion from the old diamond shaped “Hazard Communication System” to the new HCS Pictograms and Hazards is due to be implemented by June 1, 2015. We now have 6 months to re-label everything. Here's an example of the new Pictograms:

There is an easy way to get this done. All that is needed is learn all about it and put someone in charge of it's implementation then hope for the best or hire one of the companies that do this sort of thing.  Your office staff can also use this OSHA inspection checklist to see if your office meets OSHA compliance:

 

  • OSHA training should be conducted annually and documented.  Make sure that your in office OSHA manual has a section for this.

  • Documentation of training should be kept for three years.

  • Hepatitis B vaccination should be offered to clinical employees within 10 days of employment.

  • Documentation of immunity to hepatitis B vaccination must be kept on file.

  • If an employee declines the hepatitis B vaccine, the employee signature must be on file.

  • Keep the OSHA manual up to date. If you don’t have a current manual, you can use these models from the OSHA Web site at www.osha.gov/Publications/osha3186.pdf.

  • Do you have an OSHA poster? If not, download one free from this OSHA Web site at www.osha.gov/Publications/osha3165.pdf.

  • Do you have a copy of the Bloodborne Pathogen Standard? It should be in your OSHA manual. If not, you can download it from this OSHA web site at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051.

  • Keep employee record-keeping and health forms on file.

  • Keep record-keeping and health forms for the duration of employment PLUS 30 years.

  • Make sure the eyewash station works properly, has cold water only, and that a sign designates its location.

  • Keep fire extinguishers mounted on walls and currently charged.

  • Keep emergency exits marked and unobstructed.

  • Make an inspection of the office for safe work conditions such as electrical and trip and fall hazards.

  • Review evacuation plans and protocols. If you don’t have evacuation plans, you can download samples from OSHA eTools at www.osha.gov/SLTC/etools/evacuation/evaluate.html.

  • A first aid kit should be available for employees to use for minor cuts and injuries.

  • Hand hygiene policies should be in place.

  • Make sure Exposure Incident Protocol is current and reviewed annually.

  • Provide Personal Protective Equipment (PPE):

    • clinical jacket

    • protective eyewear

    • mask

    • gloves (both exam and utility)

  • Personal protective attire should be provided at no charge to employees.

  • Reusable clinical jackets should be laundered and maintained by the employer at no charge to employees.

  • Engineering controls, such as needle recapping devices or safety syringes, should be used.

  • There should be an annual review and evaluation of safer sharps devices.

  • Work Practice Controls should be employed to reduce risks when handling sharps.

  • Hazard Communication Standard must be followed:

    • Inventory of hazardous substances

    • Organize Material Safety Data Sheets (MSDS) for each hazardous substance

    • Place labels on containers not identified (secondary containers)

    • Inspect all chemical containers for leaks

    • Employees should be trained on proper use of and handling of hazardous substances

    • PPE provided for handling chemicals

    • Training and information on chemical spill, disposal, and cleanup should be provided

  • Sharps containers should be located as close as possible to where sharps are used. There must be a spill-proof container, colored red or orange-red, and it must be puncture-resistant and have a biohazard label.

  • An explanation of what labels, signs, and symbols mean (chemical, biohazard, radiation, etc.) must be provided.

  • There should be an ergonomic plan to reduce incidents of musculoskeletal injuries.

 

This is just a small sample of what the dental office is responsible for.  Considering that the dental office's prime objective is providing dental service, I recommend that an OSHA compliance company be hired to help get the office into compliance and keep it there.  A couple come to mind but there are others: Henry Schein & OSHA Review of Rancho Cordova, California.

 

Please send requests for additional information to me through the site Contact Page or DrBeber@Yahoo.com .  I'll keep you informed.

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