Inspection Directions by Leslie Canham, CDA, RDA

Training
Both the Bloodborne Pathogen and Hazard Communication standards require dentists to provide training. One of the reasons the dentist in Illinois was levied such a large fine is because he didn’t provide this training for his employees. Bloodborne Pathogen training is required every year and must be provided by the employer at no charge during regular working hours. Documentation of the training must be maintained by the employer for at least three years.

Anyone can conduct the training, which ensures that the dentist and team are current on compliance with OSHA regulations. If you don’t know where to start, these steps can point you in the right direction.

• You’ll need an OSHA manual. If you don’t have one, your state dental association may offer one; alternatively, you can purchase one from the American Dental Association. Some companies also provide OSHA manuals—just be sure that the manual is designed for dental practices. (If you have time—lots of time—you can create your own OSHA manual with written safety plans by using the tools on the OSHA website: Go to osha.gov and under the “Training & Education” pull-down menu, select “eTools.” Then click “Hospital,” “Healthcare Wide Hazards” and “Bloodborne Pathogens.”)
• Once you purchase the manual, read it. You must personalize the manual by filling in information that describes policies and procedures in your practice. The manual will ask you to fill in the names and classifications of employees; whom to contact in the event of an exposure incident; and the location and instructions for proper use of personal protective equipment. When you finish personalizing your OSHA manual, you can present the information to your dental team.

One method of team training involves having every staffer read the OSHA manual, then holding a meeting to summarize each section. Specific safety plans in the manual cover aspects of the dental office—review them and provide information about the location of the emergency eyewash station, the first-aid kit and the fire extinguisher. Give instructions on how to handle biohazard waste and contaminated sharps that have been generated in your office. Discuss your exposure-control plan and review the actions that must be taken in the event of an exposure incident. Be sure to allow time for questions and/or comments.

To help you meet the Bloodborne Pathogen training requirements, use the outline below, which recaps the 14 elements that OSHA requires:

• A written copy and explanation of the Bloodborne Standard. The standard is usually in your OSHA manual; if not, get a copy from your state or federal OSHA website.
• A general explanation of the epidemiology and symptoms of bloodborne diseases.
• An explanation of the modes of transmission of bloodborne pathogens.
• An explanation of the employer’s exposure-control plan, and how employees can obtain copies of the written plan.
• An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials (OPIM).
• An explanation of the use and limitations of methods that will prevent or reduce exposures, including appropriate engineering controls, administrative or work practice controls and personal protective equipment.
• Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment.
• An explanation of the basis for selection of personal protective equipment.
• Information on the hepatitis B vaccine, including information about its efficacy, safety and method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge.
• Information on the appropriate actions to take and people to contact in an emergency involving blood or OPIM.
• An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident, the medical follow-up that will be made available and the procedure for recording the incident on the Sharps Injury Log if sharps are involved.
• Information about the postexposure evaluation and follow-up that the employer is required to provide for the employee after an exposure incident.
• An explanation of the signs and labels and/or color coding to communicate hazards to employees.
• An opportunity for interactive questions and answers with the person conducting the training session.

In addition to Bloodborne Pathogen training, Hazard Communication training must be conducted. Employers at workplaces with hazardous chemicals must label their products, provide safety data sheets to workers and train them to handle the chemicals appropriately.

If your OSHA manual was published in 2013 or later, it likely will have a section on the new Globally Harmonized Hazard Communication Standard. Or head to osha.gov/dsg/hazcom for information on how to set up your Hazard Communication plan.

Every day, every dental practice is at risk of being investigated—and possibly shut down—if it’s not following state or federal OSHA regulations. Conduct the required trainings, review the OSHA Checklist on p. 86, and encourage every team member to help keep the practice safe and compliant. OSHA compliance gives employees confidence and creates a culture of safety and prevention.

Click here for a handy checklist that can help you determine how OSHA-compliant your practice is.

Leslie Canham, CDA, RDA, is an international speaker and consultant specializing in infection control, OSHA compliance, HIPAA regulations and treating special-needs patients. Nearly 45?years of experience in the dental field and her proficiency in OSHA give Canham a unique perspective on how dental practices can be safe, compliant and productive. She is a Certified Speaking Professional, and is authorized as an OSHA trainer and an AGD PACE provider. In addition to her speaking schedule, Canham provides in-office training, consulting, mock OSHA inspections, dental-office audits and webinars.