oshacontent.hcpro.com/manuals/meu/12cdendbl.pdf · the osha safety officer is responsible for...

About the AuthorSheila Dunn, DA, MT (ASCP), holds a doctoral degree in clinical laboratory science from the Catholic

University of America in Washington, DC. She has helped thousands of outpatient medical facilities comply

with federal regulations such as CLIA and OSHA through her presentations at a nationwide seminar series.

She has written more than 150 articles about regulatory issues and healthcare delivery systems and serves

as an advisor to numerous companies.

12C

©2005–2012. HCPro, Inc. All rights reserved, including right of reproduction. The author(s) and their agent(s) have made every reasonable effort in the preparation of this publication to ensure the accuracy of the information. However, the information in this book is sold without warranty, either expressed or implied. The authors, the editors, their agents, and the publishers will not be liable for any damages caused or alleged to be caused directly, indirectly, incidentally, or consequentially by the information in this publication. This publication cannot and does not provide specific information for a user’s exact situation. Users of this publication should exercise their own judgment and, where appropriate, seek the assistance of legal counsel regarding their particular situation.

HCPro, Inc.75 Sylvan Street, Suite A-101

Danvers, MA 01923Tel: 800/650-6787Fax: 800/639-8511

www.hcmarketplace.com

OSHAPROGRAMMANUALfor Dental Facilities

OSHA Program Manual for Dental Facilities is published by HCPro, Inc.

Copyright © 2012 HCPro, Inc.

All rights reserved. Printed in the United States of America. 5 4 3 2 1

ISBN: 978-1-60146-744-7

No part of this publication may be reproduced, in any form or by any means, without ¬prior written consent of HCPro, Inc., or the Copyright Clearance Center (978/750-8400). Please notify us immediately if you have received an unauthorized copy.

HCPro, Inc., provides information resources for the healthcare industry.

HCPro, Inc., is not affiliated in any way with The Joint Commission, which owns the JCAHO and Joint Commission trademarks.

Sheila Dunn, DA, MT (ASCP), AuthorDavid A. LaHoda, Managing EditorElizabeth Petersen, Special Projects EditorLauren McLeod, Editorial DirectorMike Mirabello, Senior Graphic ArtistMatt Sharpe, Production SupervisorJean St. Pierre, Senior Director of Operations

Advice given is general. Readers should consult professional counsel for specific legal, ethical, or clinical questions.

Arrangements can be made for quantity discounts. For more information, contact:

HCPro, Inc.75 Sylvan Street, Suite A-101Danvers, MA 01923Telephone: 800/650-6787 or 781/639-1872Fax: 800/639-8511E-mail: [email protected]

Visit HCPro online at: www.hcpro.com and www.hcmarketplace.com

03/201221961

1-5

OSHA Program Manual for Dental Facilities

Overview of OSHA Standards

All industries, including healthcare, are covered by general industry standards, 29 CFR 1910. The following standards are most applicable to the dental setting:

� general duty clause (OSH Act of 1970; SEC. 5. Duties) � bloodborne pathogens (1910.1030) � compressed gases (1910.101) � electrical safety (1910.303) � emergency action plans (1910.38) � portable fire extinguishers (1910.157) � medical services and first aid (1910.151) � personal protective equipment (1910.132) � respiratory protection (1910.134) � hazard communication (1910.1200) � occupational exposure to hazardous chemicals in laboratories (1910.1450) � ionizing radiation (1910.1096)

OSHA Inspections

OSHA is authorized by law to conduct workplace inspections to enforce health and safety standards. Not every dental office will receive scheduled, programmed inspections (usually every two years). OSHA does not have enough inspectors to oversee all workplaces under its jurisdiction, so the agency sets priorities:

1. Notices of imminent danger.2. Fatalities and catastrophes.3. Serious signed employee complaints.4. Referrals from other government entities alleging serious hazards. 5. Complaints that are not from current employees, are not signed, or do not allege a

serious hazard.6. Follow-up inspections.7. Programmed general inspections of high-hazard workplaces.

Employee ComplaintsThird in priority are employee safety complaints, which, depending on the nature of the allegation, will lead to a complaint inspection or a complaint investigation. An investiga-tion may be conducted by phone, fax, or letter.

1-6


When an anonymous employee complaint is filed via phone or letter, OSHA will contact the employer in writing, citing the allegations and requesting a written response within two weeks. The employer must respond to OSHA in writing; OSHA then provides a copy of the written response to the original complainant. Take these investigations seriously because an inadequate response will trigger an on-site inspection.

When an employee files a written, signed complaint, OSHA conducts an on-site inspection without advance notice during working hours. Smaller dental facilities are usually only inspected in response to a complaint from an employee or patient.

If an On-site OSHA Inspection OccursWhen the OSHA CSHO arrives, ask him or her to display a photo identification. Verify that the person is actually an employee of the OSHA division of the U.S. Department of Labor.

The employer should: � Ask the purpose for the inspection, its scope, and its anticipated length. � Determine which documents the OSHA CSHO wishes to inspect and under what

regulatory authority. If possible, determine which employees the CSHO intends to interview and what areas of the workplace he or she wants to inspect.

� If the inspection is based on a complaint, ask to see a copy the written complaint. Although OSHA will block out the identity of the complainant, the information will be helpful.

Employers may request a civil warrant be obtained before the inspection proceeds further. This is a 4th Amendment constitutional right, but OSHA’s right to inspect is clear, and OSHA often takes a dim view of an employer’s resistance. In the end, it is your decision whether to require a warrant or voluntarily consent to an inspection. In most cases, requiring the CSHO to obtain a warrant may help you delay an inspection, but it will not help you avoid one.

If the inspector has a warrant, records that are not specified on the warrant do not have to be provided. Be careful about providing OSHA with company documents, and don’t volunteer information! You are not required to bear the cost of making copies or allowing use of your copying equipment. Technically, if the inspector wants to copy information by hand, he may do so (29 CFR 1903.3[a]).

During the tour of your facility, the areas to be examined are specified by the inspector. If the OSHA inspector wants to see a specific area, take him or her directly there. The inspector may talk with employees, take notes, make instrument readings, take photos, and/or use a video camera.

5-9


Transmission of Bloodborne PathogensThe most common modes of transmission in the workplace due to contact with blood and other potentially infectious substances are:

Direct inoculation into a preexisting skin lesion (splash or spray onto non-intact skin).Needlesticks.Sharps injuries from broken glass, dental instruments, etc.Mucous membrane contact through sprays, splashes, rubbing into eyes, nose, mouth, etc.

In this facility, instances where bloodborne pathogens may be transmitted in the workplace are identified and engineering and work practice controls have been implemented. Personal protective clothing and equipment is also provided to applicable employees.

Exposure Determination

Personnel Who Are Occupationally Exposed

Complete the Exposure Determination List #1, located behind Tab 8: Master Record Forms (Form 7), specifying all the positions (job titles) in the facility for which there is definitely the risk of occupa tional exposure. List dentists, hygienists assistants and any other employee category that is occupationally exposed to blood and saliva in your facility. These employees may be referred to as Class I employees.

Note that those employees who could be exposed to blood and OPIM only from voluntarily assisting a fellow employee (e.g., “Good Samaritan” acts) are not expected to be included on either Exposure Determination List.

Exposure Prone Procedures

Examples of procedures that could expose employees to blood and potentially infectious substances are shown below. Use a check mark to indicate procedures done in your facility.

Treatment procedures Radiographic procedures

Instrument processing Flushing equipment lines

Handling dental impressions Giving injections

Laboratory procedures Cleaning/servicing contaminated equipment

Handling contaminated laundry Handling extracted teeth

Collecting filled sharps containers Handling and disposing of hazardous waste

Cleaning blood, saliva spills Cleaning blood or saliva from patient care areas

5-10


Exposure to infectious body fluids and transmission of disease can occur through direct or indirect contact with an infected person. Examples of exposures are:

Putting hands into the mouth of an infected person.Touching the blood or saliva from an infected person.Being splashed with blood or saliva, which enters through the mucous membranes of the

eyes, nose or mouth.Touching contaminated instruments, equipment, work surfaces, or waste.Receiving a cut or puncture wound from a sharp instrument or needle.Touching impressions, dentures, or other objects that have been in the patient’s mouth.Having contact with airborne microorganisms in splatter or aerosolized debris.

The following is a list from OSHA’s Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens of healthcare job classifications that may be associated with tasks that have occupational exposure to blood and other potentially infectious materials. The scope of the standard is not limited to employees in these jobs, according to the Enforcement Procedures.

Physicians, physician’s assistants, nurses, nurse practitioners, and other healthcare em-ployees in clinics and physicians’ offices; employees of clinical and diagnostic laboratories; housekeepers in healthcare and other facilities; personnel in laundries that service healthcare institutions; tissue bank personnel; employees in blood banks and plasma centers who collect, transport, and test blood; freestanding clinic employees (e.g., hemodialysis clinics, urgent care clinics, health maintenance organization (HMO) clinics, and family planning clinics); employees in clinics in industrial, educational, and correctional facilities (e.g., those who collect blood, and clean and dress wounds); employees designated to provide emergency first aid; dentists, dental hygienists, dental assistants and dental laboratory technicians; staff of institutions for the developmentally disabled; hospice employees; home healthcare workers; staff of nursing homes and long-term care facilities; HIV and HBV research laboratory and production facility workers; employees handling regulated waste; custodial workers required to clean up contaminated sharps or spills of blood or OPIM; medical equipment service and repair personnel; emergency medical technicians, paramedics, and other emergency medical service providers; maintenance workers, such as plumbers, in healthcare facilities and employees of substance abuse clinics.

5-35


Examples of PPE provided in this facility are:

PPE Locations

Gloves (latex)

Gloves, latex (non-powdered)

Gloves (non-latex)

Gloves (utility)

Gowns, aprons or other fluid-resistant outerwear

Face protection (goggles, masks,

shields)Mouthpieces, other

resuscitation devices

Other

The OSHA Safety Officer is responsible for seeing that adequate supplies of PPE are main-tained. Report low stock levels of PPE to the OSHA Safety Officer. Do not reuse disposable personal protective equipment that is contaminated–dispose of it immediately.

Those who wear PPE must examine it before each use and replace, if necessary. Do not use PPE if it is damaged to the point of not maintaining its effectiveness. If PPE is penetrated by blood or other potentially infectious material (OPIM), remove it as soon as possible and dispose of properly. Employees must also remove PPE prior to leaving the work area. Used PPE may be disposed in regular trash unless visibly contaminated with blood or OPIM.

Wearing the required PPE is not optional. Employees may not decide to routinely decline the use of PPE due to inconvenience or personal preferences. However, rare exceptions may exist when, in the employee’s professional judgment, PPE use would:

Prevent the delivery of health care or public safety services; orPose an increased hazard to the employee’s safety or that of coworker(s)

When employees exercise judgment to decline the use of PPE, our organization investigates and documents the incident to determine whether changes can be made to prevent such occurrences in the future (See Form 8-A1). Employees are encouraged to report all such instances without fear of reprisal.

GlovesWearing gloves to provide a protective barrier to organism transmission has become standard

5-36


practice in all clinical settings today. However, extreme variability in the quality of gloves has been widely reported. Leakage and tears have been reported to be as high as 59% in some cir cumstances with some glove varieties. So select gloves carefully. Plastic film food handling gloves (“cafeteria” or “baggie” gloves) are not considered to be appropriate for use in exposure-related tasks.

Wear gloves in any situation where hands could come into contact with blood or other potentially infectious materials. Also wear gloves when handling or touching contaminated items or sur-faces. Wash hands immediately after removing gloves.

When to Wear Gloves

When touching patient mucous membranes or non-intact skin.While performing phlebotomy and other vascular access procedures.When processing body fluid specimens.While performing fingersticks or heelsticks.When touching items contaminated with blood or body fluids.While treating lacerations, abrasions, and compound fractures.

Workers should also wear gloves when they have hangnails, chapped hands or other abrasions on the hands.

How to Wear Gloves

Wear gloves that fit properly. Place them to fit over your sleeve cuff. Before donning gloves, check for tiny punctures, discoloration, and other physical

defects. Do not wear defective gloves.Remove gloves before handling non-contaminated items such as telephones and when

leaving the area. Change gloves between patient contacts. Never wash or disinfect latex or vinyl gloves

for reuse.Remove gloves in a way that minimizes contamination to hands and production of aerosols. Wash hands immediately after removing gloves.

Never assume that wearing gloves is foolproof protection–even if the integrity of the glove is not compromised, the act of taking it off could lead to exposure. Moreover, gloves provide a barrier to contact, but neither vinyl nor latex procedure gloves are completely impermeable.

Replace gloves when they are torn, punctured, contaminated, or when their ability to function as a barrier is compromised. Disinfecting agents and petroleum-based hand creams may cause exam glove deterioration. Washing with surfactants could result in wicking (penetration of liquid into the glove via undetected pores). For these reasons, never wash or re-wear latex and vinyl exam gloves.

While disposable gloves must be replaced as soon as practical when contaminated, obviously some critical procedures (i.e., surgery) cannot be interrupted to change gloves. The key words to evaluate are “practical” and “feasible.”

TAB 8: MASTER RECORD FORMS

Contents

General Equipment and Facility RecordsForm 1 Safety Report…………………..…................ Use to document employee complaints; staff

meeting minutes.Form 2 Autoclave Log…………………..………........ Use weekly or as indicated to record performance of

biological indicator tests.Form 2-A Eyewash Station Weekly Check Log........... Use weekly to record performance of emergency

eyewash station.Form 3 Annual OSHA Safety Program Review….... Use annually to document that this manual was

reviewed and updated.Form 4-A Weekly Facility Review Checklist................ Use weekly (optional form).

Form 4-B Monthly Facility Review Checklist................Use monthly (optional form).

Form 5 Annual Facility Review Checklist…….......... Use annually.

Form 5-A Fire Drill Evaluation Form.............................Use at least once per year

Form 5-B Employee Fire Drill Participation Sign-up Sheet...............................................

Use at least once per year

Form 6 Housekeeping Schedule………..…….......... Use initially.

Form 6-A Healthcare Facility Slip, Trip, and Fall Hazard Checklist....................................

Use as needed.

Bloodborne Pathogens RecordsForm 7 Bloodborne Pathogens Exposure

Determination List #1………………….........Use initially and whenever new clinical staff is added.

Form 8 Bloodborne Pathogens Exposure Determination List #2………………..….......

Use initially and whenever new clinical staff is added.

Form 8-A Bloodborne Pathogens PPE Compliance Checklist…………..…...….......

Use periodically to monitor compliance with the PPE sections of the bloodborne pathogens standard.

Form 8-A1 Failure to Use PPE..................................... Use to investigate incident.Form 9 Safety Needle/Syringe Evaluation Form…. Use initially and whenever new safety devices are

under consideration.Form 9-A Sharps Disposal Container Locations......... Use periodically to monitor compliance for sharps

disposal container locations.Form 9-B Bloodborne Pathogens Compliance

Checklist: ECP, Training, and Records........Use periodically to monitor compliance for sharps disposal container locations.

Form 10 Sharps Evaluation Results Form…….......... Use initially and whenever new safety devices are under consideration.

Form 10-A Exposure Prevention Checklist.................... Use periodically to monitor compliance for sharps disposal container locations.

Contents

Bloodborne Pathogens Employee Medical RecordsForm 11 Accident Report/Sharps Injury Log.............. Use when an employee injury occurs, including sharps

injuries and other bloodborne pathogens exposures. Form 11-A Sharps Injury Log.........................................Use to compile sharps injury device data for

sharps evaluation.Form 12 HBV Vaccination Declination Form……....... Use when an employee is given the hepatitis B vaccine

or declines this vaccine.

Form 13 HBV Employee Vaccination Form…….........Use when an employee is given the hepatitis B vaccine or declines this vaccine.

Form 14 Post-exposure Checklist…………….…........Use to document that all required actions were taken after a sharps injury or employee exposure to bloodborne pathogens.

Form 15 Post-exposure Medical Evaluation Declination Form………………….................

Use to document a particular employee refusing post- exposure testing and treatment.

Form 16 Source Patient Testing Consent Form…………………..…..…..........

Use to obtain consent from a source patient after an exposure incident such as a needlestick.

Hazard Communication Records Form 17 Hazardous Substances List…….……......... Use initially to list all hazardous chemicals in

your facility and when a new hazardous chemical is introduced.

Form 18 MSDS Request Letter…………..…….......... Use when a new hazardous chemical is intro duced to document attempts to procure a MSDS.

Training RecordsForm 19 New Employee OSHA

Orientation Checklist……………………......Use to document initial OSHA training when new staff members are added.

Form 20 Annual Employee Training Record….......... Use annually.

Form 20-A Respiratory Protection Training Record……Use annually.

TB / Infection Control Records Form 21 TB Risk Assessment Results Form…......... Use annually.

Form 22 TST Record……………..………………....... Use as indicated, based on your facility’s risk assessment.

Form 23 TB Skin Test Declination Form………......... Use when an employee declines receiving a TB skin test.

Form 24 TB Exposure Log……………….…...…........ Use as indicated when employees are exposed to a known TB patient.

Form 25 Influenza Vaccine Log………....………........ Use annually to vaccinate all employees.

Form 25-A Influenza Vaccine Declination Form….......... Use when an employee declines this vaccine.

Form 25-B Checklist for Infection Prevention for Outpatient Settings.........................................

Use initially and at least annually thereafter.

Form 25-C List of Infection Prevention Contact Persons and Roles/Responsibilities..............................

Use initially and whenever infection prevention roles and responsibilities change.


Form 8-A1

FAILURE TO USE PPE

Employees may not decide to routinely decline the use of PPE due to inconvenience or personal preferences. Use this form, however, to investigate rare occasions when PPE was declined because use would:

• Prevent the delivery of health care or public safety services; or

• Pose an increased hazard to the employee’s safety or that of coworker(s)

Procedure/Task/ Location Type of PPE Reason for

declining PPE use Employee name Date

Summary of investigation: ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Investigator: _______________________________________________________________________________

Date of improvement or action:____________________________________________________________

Description of improvement or action taken:___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

oshacontent.hcpro.com/manuals/meu/12cdendbl.pdf · the osha safety officer is responsible for...

Documents