Dental OSHA Compliance Services, LLC

07/02/2020

New Expectations in Dentistry Amid the Coronavirus Pandemic- email me for additional information [email protected]

Many dental offices have begun to open after being shut down for two months due to the Coronavirus. Concerns for the health and welfare of both the staff members and patients must be considered when reopening. Because Dentistry is one of the highest exposure industries, it is important for dental offices to abide by the updated protocols for infection control. The new set of guidelines must be in place and adhered to as part of the Interim Transmission Based Infection Control Precautions that the CDC and OSHA have adopted. Now is the time to embrace and implement these new protocols.

Before opening make sure all equipment is working properly, especially the sterilizers. It is also important to test the water lines to see what the CFU (colony forming units) levels are for each room prior to seeing patients. I recommend using the Quick Pass in house testing by Pro Edge. If necessary, the lines should be shocked and dental waterline treatment protocol must be implemented according to the manufacturer’s instructions of the product you are using. Make sure to flush the water lines in each operatory for two minutes before seeing the first patient, and then routinely after each procedure for 20 to 30 seconds.

Make sure you have enough Personal Protective Equipment for each employee before opening. There has been a shortage due to the increased need of medical personnel and the limitations of manufacturing in the U.S. Verify the PPE being purchased is approved by the CDC and NIOSH. The link to check for approved masks is: https://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/N95list1-a.html. Some KN95 masks have been removed due to testing failures so it is important to confirm masks are approved and safe. An initial qualitative fit test must be performed to make sure the fit is acceptable, however, the quantitative portion of the fit test has be waived due to the Covid 19 circumstances.

Prior to seeing patients, it is important to have a staff meeting to review new protocols and practice expectations. If you have already opened and have not implemented the guidelines, it would be a good idea to do so now. OSHA has announced that it will be increasing its in-person inspections due to the Covid 19 threat.

The new mandates make it necessary to have a written procedure for Transmission Based Infection Control as an addition to your current OSHA Infection Control processes in the practice. It must include the following:

· Screening employees before returning to work and take temperatures on each employee before seeing patients every day

· Remove all items in the waiting room that cannot be disinfected (i.e. magazines & toys)

· Place signage for respiratory hygiene and cough etiquette in the waiting room

· Prescreen patients for potential illness or exposure prior to their appointment

· Schedule patients to minimize contact with other patients

· Advise patients to come alone to appointments unless patients are children, elderly or special needs requiring assistance

· Patient’s temperature taken and recorded upon arrival

· Patient to be given hand sanitizer upon entering the office

· Patient should wear a mask until procedure begins

· All staff members must continue adherence to standard precautions but must also implement Transmission-Based Precautions using an N95 mask or equivalent for all DHCP exposed to aerosols

· Face-shields should be used

· Fluid resistant lab gowns must be worn

· Scrub cap or bouffant cap must be worn

· Shoe covers should be worn

· Follow proper protocol for donning and doffing PPE

· DHCP remains in the room once procedure has begun

· Schedule to allow extra time for disinfection and operatory preparation

· Cavitron, Prophy Jet and Piezo procedures to be suspended until further notice

· All patients must rinse with a hydrogen peroxide-based mouthwash prior to treatment for 30 seconds (Peroxyl or Listerine Whitening are good choices)

· Reduce aerosols by using additional suction devices,(recommendations are Isolite, Releaf, & Dry Shield for intraoral and ADS Extraoral Suction device for extraoral), reduce water output on handpieces, and do not use air and water together on air/water syringes

· After procedure, disinfect air with Lysol and use surface disinfectants for maximum kill time

· Take off all PPE before leaving the operatory

· Wash hands immediately

· Utilize safe and practical protocols for laundering clinical attire- (it is ideal to have an onsite washer/dryer for use) – no clinic attire is to be worn outside the office to avoid cross-contamination

If you follow these recommendations for implementing the new protocols that are now required in the dental setting, it should help in obtaining office compliance. It is important to have everyone in the office trained and committed to the observance of the directives to reduce the possibility of exposure and cross contamination. By having a meeting ahead of time and reviewing the expectations, everyone will have the information they need to keep themselves and their patients safe.

This page contains a suppliers list of NIOSH-Approved N95 Particulate Filtering Facepiece Respirators. A Suppliers List

06/19/2020

Looking for help with compliance?

8 Tips to become compliant easier and faster

Have you found it hard to navigate the requirements of Dental Compliance? Have you been confused when trying to find all the OSHA requirements an office must implement as well as the state requirements? Are you looking for help with your compliance? Would you like to have your OSHA made easy? Here are 8 tips to make your compliance journey easier and faster:

1. Create a Culture of Compliance.

The dentist or the owner of the practice should set the expectation of compliance. They are the Captain of the ship. The leader whom everyone looks to for guidance. If the Captain believes in safety protocols and systems, the crew will also.

2. Assign a Compliance Coordinator for your office.

This is usually someone who works in a clinical capacity or an office manager. This person is like the navigator of the ship plotting the course of the journey. This person is in charge of directing the process. They will make sure all deadlines are met, all documentation is recorded, all training is completed and all systems are in place. They should delegate key responsibilities to the staff to make sure things get done in a timely manner.

3. Hire the right Compliance Consultant.

This person should be there to answer compliance questions after the training is finished. Many times, a trainer comes into your office or you go to hear them speak at a continuing education course and you never hear from them after the training. You can’t reach them. They won’t call you back and they won’t respond to your emails. A good Compliance Consultant will take the time to help you through the compliance process by being accessible when their clients need them.

4. Set a realistic timeline to complete office compliance.

I have seen this many times. An office wants to get everything done in two weeks. They become overwhelmed and confused. If you are just starting your compliance journey, it will most likely take you several months to have everything in place. There are a lot of tasks to complete. This takes time. The best thing you can do is be realistic with the project so you won’t be crushed under the weight of the requirements.

5. Make it a team effort.

Everyone on the team has a role to play and a job to do. Just like the crew on a ship, everyone participating and contributing will get the job done…. FASTER. And more effectively.

6. Use your checklists.

Your Compliance Consultant should give you a list of tasks and duties to complete. When you follow a checklist, this makes it easier and more efficient to complete the project. The checklist is like the ship’s compass. It will give you a direction with systems organization and guidance.

7. Do the small tasks first.

This way when you complete several of the many requirements, it feels like you have accomplished something. You get the smaller and easier tasks out of the way to focus on the bigger items. It will not feel as if you have as much looming over your head. This helps you to not become overwhelmed.

8. Have regular compliance meetings.

In the beginning, I recommend having one training session, and then updates once a month until all tasks, plans and documentation are completed. After that, then have your annual training and then a subsequent compliance meeting to go over and maintain your systems and records.

If you follow these steps and adhere to the system, I promise it will make the process of becoming compliant easier to navigate.

06/15/2020

Conducting Respirator Fit Tests and Seal Checks

What is a fit test?

According to OSHA, “a ‘fit test’ tests the seal between the N95 mask’s, or respirator's, facepiece and your face.” It typically takes 15-20 minutes to complete and should be performed when this type of mask is first used and then at least annually. The purpose of the fit test is to assure that the mask fits and seals properly so potentially contaminated air cannot leak into the mask and so hazardous substances are kept out.

The fit test must be conducted using the same make, model and size of mask that the worker will use on the job. Fit testing with a different type of mask than the one that will be used does not assure proper protection.

If the model of mask used for the fit test does not properly fit, another make, model, style, or size of mask must be tested until one that fits properly has been identified.

Employers need to provide staff with a reasonable selection of sizes and models if available, to try. Once the fit test is completed and the wearer knows which mask fits best, he/she should always use the one shown to be the right ‘fit’ or ‘size.’ That way, it can be replaced with another mask with appropriate fit.

Fit tests can be qualitative or quantitative. In dentistry, the qualitative test is most often used.
*Qualitative fit testing is normally used for half-mask respirators like the N95, which cover only the user’s mouth and nose.

Qualitative fit tests operate on a pass/fail method and do not measure the actual amount of leakage. They rely on the user’s sense of taste or smell, or the person’s reaction to an irritant, to detect leakage. The mask fails the test if the wearer can detect any leakage of the test substance. OSHA has accepted four qualitative fit test methods:
1. Isoamyl acetate, which smells like bananas;
2. Saccharin, which leaves a sweet taste in your mouth;
3. Bitrex, which leaves a bitter taste in your mouth;
4. Irritant smoke, which causes coughing.

Information on quantitative fit testing can be found on OSHA’s website. The agency’s resource, Appendix A to §1910.134—Fit Testing Procedures (Mandatory):

Part I. OSHA-Accepted Fit Test Protocols: A. Fit Testing Procedures—General Requirements, offers helpful guidance.

Mask fit should be reevaluated any time the wearer experiences changes in his/her physical condition that could affect the fit. These include: a significant change in weight (either loss or gain); major dental work, such as new dentures; facial surgery that changes the shape of the face; or significant scarring in the area around the seal.

Employers must ensure that the fit testing and recordkeeping requirements of OSHA's respiratory protection standard are met before staff can use a N95 mask for protection against hazardous exposures at work. Employers may allow personnel to use their own respirators but cannot require them to do so.

Conducting Respirator Fit Tests and Seal Checks

Why does it have to be done annually?
OSHA requires that training and fit testing be done every year, before or on the anniversary date of the employee's previous training and fit test to ensure proper protection.

How do I do a seal check?

OSHA has released a video
https://www.youtube.com/watch?v=6qkXV4kmp7c,

How to Perform a User Seal Check with an N95 Respirator, to offer guidance for conducting the mask seal check.
A seal check is a quick check performed by the wearer each time the mask is put on. It determines if the mask is properly seated to the face or if it needs to be readjusted. It is not a substitute for a fit test. There are two types of seal checks: the positive pressure check and the negative pressure check.

To conduct a positive pressure check:
Don and adjust the mask for proper fit. Then, exhale gently into the facepiece.
The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal.

https://www.youtube.com/watch?v=bo-PEzHE7iw

To conduct a negative pressure check:
Don and adjust the mask for proper fit; then inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds.
If the facepiece remains slightly collapsed and no inward leakage of air is detected, the tightness of the mask is considered satisfactory.

Users can opt instead to perform a seal check by following the N95 mask manufacturer's recommended procedures as long as the employer can demonstrate that the manufacturer's procedures are equally effective. Always be sure to follow the manufacturer’s specific instructions for conducting a seal check and be sure to fully inspect the complete respirator, including the straps, to ensure that no damage has occurred.

When using a respirator that has a metal strip that fits over the nose, be sure to carefully press the strip down to ensure that the nosepiece fits closely and provides a full seal. Always be sure to remove the respirator without touching the exterior since it could have been contaminated.

What is the fit testing expectation for KN95 masks?
There is no guidance available on the OSHA’s website for testing KN95 masks.

Disclaimer. These materials are intended to provide helpful information to dentists and dental team members. They are in no way a substitute for actual professional advice based upon your unique facts and circumstances. This content is not intended or offered, nor should it be taken, as legal or other professional advice. You should always consult with your own professional advisors (e.g. attorney, accountant, insurance carrier). To the extent ADA has included links to any third party website(s), ADA intends no endorsement of their content and implies no affiliation with the organizations that provide their content. Further, ADA makes no representations or warranties about the information provided on those sites.

06/14/2020

This is good information!

http://dentalenhancements.com Top 5 OSHA compliance requirements for your dental office Do you consider your dental practice to be OSHA inspection ready? If so, congratulations! If you have some doubts, here are some tips that may help you out. 1. Is your OSHA manual up to date? Even if your manual....

06/13/2020

Looking for help with compliance?

8 Tips to become compliant easier and faster

Have you found it hard to navigate the requirements of Dental Compliance? Have you been confused when trying to find all the OSHA requirements an office must implement as well as the state requirements? Are you looking for help with your compliance? Would you like to have your OSHA made easy? Here are 8 tips to make your compliance journey easier and faster:

1. Create a Culture of Compliance.

📷

The dentist or the owner of the practice should set the expectation of compliance. They are the Captain of the ship. The leader whom everyone looks to for guidance. If the Captain believes in safety protocols and systems, the crew will also.

2. Assign a Compliance Coordinator for your office.

📷

This is usually someone who works in a clinical capacity or an office manager. This person is like the navigator of the ship plotting the course of the journey. This person is in charge of directing the process. They will make sure all deadlines are met, all documentation is recorded, all training is completed and all systems are in place. They should delegate key responsibilities to the staff to make sure things get done in a timely manner.

3. Hire the right Compliance Consultant.

📷

This person should be there to answer compliance questions after the training is finished. Many times, a trainer comes into your office or you go to hear them speak at a continuing education course and you never hear from them after the training. You can’t reach them. They won’t call you back and they won’t respond to your emails. A good Compliance Consultant will take the time to help you through the compliance process by being accessible when their clients need them.

4. Set a realistic timeline to complete office compliance.

📷

I have seen this many times. An office wants to get everything done in two weeks. They become overwhelmed and confused. If you are just starting your compliance journey, it will most likely take you several months to have everything in place. There are a lot of tasks to complete. This takes time. The best thing you can do is be realistic with the project so you won’t be crushed under the weight of the requirements.

5. Make it a team effort.

📷

Everyone on the team has a role to play and a job to do. Just like the crew on a ship, everyone participating and contributing will get the job done…. FASTER. And more effectively. 📷

6. Use your checklists.

Your Compliance Consultant should give you a list of tasks and duties to complete. When you follow a checklist, this makes it easier and more efficient to complete the project. The checklist is like the ship’s compass. It will give you a direction with systems organization and guidance.

7. Do the small tasks first.

📷

This way when you complete several of the many requirements, it feels like you have accomplished something. You get the smaller and easier tasks out of the way to focus on the bigger items. It will not feel as if you have as much looming over your head. This helps you to not become overwhelmed.

8. Have regular compliance meetings.

📷

In the beginning, I recommend having one training session, and then updates once a month until all tasks, plans and documentation are completed. After that, then have your annual training and then a subsequent compliance meeting to go over and maintain your systems and records.

If you follow these steps and adhere to the system, I promise it will make the process of becoming compliant easier to navigate.