OSHA Compliance for Dental Facilities
By Karson L. Carpenter D.D.S.
A small business such as a dental office has a multitude of legal requirements that must be met. While they all are important, none is more important than OSHA compliance, because it not only makes your facility safer for all who work there, but eliminates your exposure to costly and embarrassing fines.
There is often considerable misunderstanding as to what OSHA regulates and many confuse OSHA requirements with infection control recommendations. OSHA, in fact, is concerned with only one thing—the safety of employees. OSHA, which is an acronym for the Occupational Safety and Health Administration, was formed through an act of Congress and its requirements are federal law. OSHA does not care if the hazard is from a chemical, a bloodborne pathogen, an electrical device or a fire. The only concern it has is the protection/safety of the worker, and this includes all employees in the dental profession.
To begin your compliance efforts, choose someone to be your Safety Compliance Coordinator (SCC). A trusted and organized dental assistant, hygienist or officer manager is suggested; by having an accountable individual, progress can quickly be made. Next, assign your SCC to review and implement one step at a time, using the following outline:
Hazard Communication Standard
The Hazard Communication Standard deals with hazardous chemicals in the workplace. In dentistry, these include disinfectants, restorative materials, acids, cleaners, impression materials, etc. This Standard requires a written chemical safety plan, material safety data sheets for each hazardous chemical/product, labeling of these potentially hazardous products and training of employees who are exposed to them.
The Globally Harmonized System for Hazard Communication
The Occupational Safety and Health Administration (OSHA) has decided to adopt the Globally Harmonized System for Hazard Communication (GHS) in the United States. The GHS, as the name implies, is a way of communicating chemical safety hazards in a consistent manner throughout the world.
This new system utilizes Safety Data Sheets (SDS) and labeling that will be identical for the same chemical no matter if it was manufactured in Europe, Asia or North America. This will not only enhance the protection of both people and the environment, but will facilitate international trade. For example, in the dental industry, many products come from the United States, Japan and Germany. Once GHS is fully enacted, health care workers will see the same type of product labels and SDS on all of the products they purchase—no matter what the country of origin.
Bloodborne Disease Pathogens Standard
Because dental office employees are exposed to blood and saliva every day, this Standard is an extremely important one. Requirements include having a written Exposure Control Plan, providing the Hepatitis B immunization at no cost to exposed employees, and making available personal protective equipment (mask, gloves, safety eyewear, long-sleeved protective clothing). In addition, employees must have inter-departmental meetings at least annually to consider safer medical devices. As with all OSHA regulations, training is paramount. Employees must understand the modes of transmission for bloodborne diseases such as Hepatitis B, Hepatitis C, and HIV. They must also know what to do in the event of a needle stick or other exposure incident and have access to proper follow-up medical care.
Electricity is such a normal part of everyday life that is often overlooked as being potentially dangerous. Everyone has experienced a minor shock, but may fail to realize that severe shocks can cause death. Dental facilities make considerable use of electrical devices including autoclaves, instrument washers, ultrasonic cleaners, model trimmers, lathes and curing lights, as well as a host of others. It is important that no extension cords be used, that plugs and cords are checked for wear/ intact insulation and that plugs match their outlets (e.g. three-pronged). In addition, cords should not be twisted around each other, but should run in parallel, and circuits/outlets must not be overloaded.
OSHA regulations require an employer to evaluate their facility for any potential radiation hazard and provide employees with the appropriate training and monitoring equipment. The only source of ionizing radiation in a dental office is radiographic equipment. While some states require the wearing of radiation badges by dental workers, others do not. It is recommended though, that workers who take radiographs (assistants and hygienists) wear monitoring badges, since there is no such thing as a totally safe dose of ionizing radiation.
Means of Egress
Every building is required by law to contain adequate exits that allow for escape of all occupants in case of fire or other emergency. There must be at least two of these means of egress in every building. Exits must have no locks or fastening devices that may prevent free escape and must be clearly visible and conspicuously marked with illuminated or glow-in-the-dark signs. Non exits need to have similar signs that state “Not an Exit.” In the event of power failure, reliable emergency lighting must also be available for all exits and signs.
Walking and Working Surfaces
This part of the OSHA regulation is often called the housekeeping standard. It requires all rooms and passageways to be kept clean, orderly and sanitary. All aisles and hallways must be kept free of debris/clutter and floors must be kept clean and dry. Additionally, stairways must have railings/guardrails and any ladders used must be OSHA approved.
Ventilation in the dental office is very important, as a variety of potentially hazardous substances can become airborne and cause illness or injury. To identify if a substance is hazardous in the form of a gas, fume, vapor or dust, consult the appropriate material safety data sheet or product label. One of the best recommendations is to put the heating/cooling system fan in the “on” position during working hours to allow for adequate turnover of air in the office. In addition, encourage the proper use of high volume evacuation during restorative procedures or any other procedures involving rotary instruments. If working with monomers or other volatile liquids in the lab, use the vent fan or a vent hood. For those offices that use nitrous oxide, remember to use your scavenger system and test for nitrous levels in the air on a quarterly basis.
Medical and First Aid
This part of the OSHA regulation does NOT dictate what type of medical drugs and/or equipment you have in place for patient medical emergencies, as is often thought. Remember that OSHA regulations are only concerned with employee safety. The requirements include having medical personnel available to provide emergency care if needed or to have an employee(s) trained in first aid available during working hours. A first aid kit should be available for self-aid as well as CPR microshields or other barrier devices to use when performing resuscitation. Remember to have emergency numbers posted on the phone and to have an eyewash station installed for flushing of the eyes.
OSHA requires fire safety training. This training must include reviewing a list of all flammables in the workplace and their possible ignition sources. Employees must also know what their responsibilities are in the event of fire and the location of a safe meeting place after evacuation. Having an accessible fire extinguisher and training employees on its proper use is also required.
As in so many other areas, proper recordkeeping is mandatory. Requirements include employee medical records, records of training, environmental monitoring records (results of nitrous oxide and radiation testing) and material safety data sheets archiving. Employees have a right to access these records and they must be allowed to do so within 15 days of their request.
OSHA requirements for dental offices are nothing more than a safety program for its employees. By appointing a Compliance Director and making him/her accountable, rapid progress can be made. If their time is limited, it may be advisable to consider a commercially prepared program to guide them through the process.
Karson L. Carpenter D.D.S. serves as President and CEO of Compliance Training Partners. He has over 25 years’ experience designing educational programs to bring dental facilities into compliance with governmental regulations including OSHA, HIPAA, and infection control.