How to protect your practice and your employees from the start
The Occupational Safety and Health Administration (OSHA) requires dentists to provide training to employees who have occupational exposure to bloodborne pathogens. Training must be conducted at the time of initial assignment, then at least annually and when new tasks or procedures affect the employee’s occupational exposure. This article will provide a step by step checklist to help launch your office OSHA program.
OSHA Manuals
The first step is to purchase an OSHA manual. A good place to buy one is from your state dental association. If they don’t have one, then get the Regulatory Compliance Manual from the American Dental Association. Next, open the manual and personalize each section by filling in the blanks. The manual may ask for the names and job classifications of employees, persons to contact in the event of an exposure incident, and the location and instructions for proper use of personal protective equipment. Once you have filled in the information, these sections become the site specific written plans as required by OSHA.
Training
When you have finished personalizing your OSHA manual, you can present the information to your employees. One method of training is to have employees read the OSHA manual, then hold a staff meeting to summarize each section of the manual. Discuss your exposure control plan and review the actions that must be taken in the event of an exposure incident. Also, review the safety plans, and provide information as to the location of the emergency eyewash station, first aid kit, and fire extinguisher. Give instructions on how to handle biohazard waste, chemicals and sharps. Be sure to allow time for questions and/or comments. Document the training and retain the training records for a period of three years.
Hepatitis B Vaccination
The Hepatitis B vaccination must be offered within 10 days of employment to all employees who have occupational exposure. The vaccination, which is a series of three injections, is the responsibility of the dentist to provide at no charge. Employees will either accept the employer’s offer of the Hepatitis B vaccination or sign a declination form. Employees who decline may request the vaccination at a later date at no cost.
Hazard Communication
Chemicals used in dentistry can cause a wide range of health hazards (such as irritation, sensitization, and carcinogenicity) and physical hazards (such as flammability, corrosion, and reactivity). OSHA requires dentists to prepare and implement a written hazard communication program to inform employees about these hazards. Your OSHA manual will have a section on Hazard Communication to help you meet this requirement. In addition to the written plan, employers must ensure that all containers of hazardous chemicals are properly labeled and that employees have access to the manufacturer’s Material Safety Data Sheet (MSDS). The best way to start an MSDS book is to collect the MSDS as each new product is delivered. You can go online to the manufacturer’s website to obtain an MSDS any products that don’t have one. Compile all the MSDS pages, highlight the product name and place in alphabetical order in a binder. Employees must also receive training on how to use the products, what protective attire is required and how to handle chemical spills and exposures.
Fire Safety
The employer must develop and implement a written plan that covers all the actions that employers and employees must take to ensure employee safety in the event of a fire. In addition to the written fire safety plan, the employer must provide approved portable fire extinguishers which should be mounted on the wall and within a travel distance of 50 feet or less. Fire extinguishers must be maintained, fully charged, operating properly, and kept in designated places at all times except during use. The employer must make sure that exits are unobstructed and signs indicate their location.
To help dentists meet the OSHA training requirements, below is a checklist of the 14 elements of an Annual Bloodborne Pathogen Program. For more information you can go online to the OSHA website www.osha.gov. For a complimentary copy of a New Employee OSHA Training Checklist send me an email [email protected].
14 Elements of a Bloodborne Pathogen Training Program
- A written copy and explanation of the Bloodborne Pathogen Standard.
- 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 the means by which the employee can obtain a copy 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 Material (OPIM).
- An explanation of the use and limitations of methods that will prevent or reduce exposure 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 (PPE).
- An explanation of the basis for selection of personal protective equipment.
- Information on the hepatitis B vaccine, including information on its efficacy, safety, 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 persons 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 on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following 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.