Compliance with Government Regulations
There are several government regulations in the dental office that you will deal with on a regular basis and that will affect your practice on a daily basis. The Occupational Safety and Health Administration (OSHA), the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and the Centers for Disease Control and Prevention (CDC) are the specific areas of regulation addressed in this chapter. Obviously, these areas are not exhaustive within the scope of government regulation. For example, employment law is covered in another chapter in this book, and amalgam waste management is not addressed here (refer to the American Dental Association website listed in the references section). Government regulations in the areas of OSHA, HIPAA, and the CDC have changed how dentists practice and will continue to do so in the future.
The basic answer: OSHA was created to oversee compliance with the Occupational Safety and Health Act passed by Congress in 1970. This is a worker safety law. Before this law, as an employee you were left to the goodwill of your employer as to whether your workplace was safe or not. For example, when building San Francisco’s Golden Gate Bridge, the engineer insisted that it be a safe workplace. He insisted on tethers for all workers working on the high wires and even built a net under the entire bridge to catch anyone who fell. Even with these precautions, eleven men died during the construction. These workers were lucky. Brooklyn Bridge workers were not so fortunate. Twenty to thirty men died during its construction—the number being uncertain because records were not kept with any consistency. Because of this law, many lives are saved on a daily basis across many industries.
Many people in healthcare sometimes lose sight that OSHA is a worker safety program and not a patient safety program. In fact, most of the subparts of the OSHA law have nothing to do with healthcare-specific items, and even those sections can apply to any industry. This law has to be broad because it applies to all employers who have employees.
We discuss the subparts of this law and the specific applications to the dental office. It is your responsibility to provide a safe workplace for any employee. This is not only the right thing to do, it is the law.
Walking and Working Surfaces
This, like many of the subparts, is common sense–oriented. It has to do with safety requirements for aisles and passageways, guardrails, and the use of ladders. Basically it requires you to keep all passageways clear of debris or any obstacle that would prevent safe travel in that area. This could include a wet floor, a rug that causes tripping, or storage of inappropriate items in these areas. The ladder portion refers to the act of making sure the ladder is in good condition and that another person holds the ladder for the person climbing it. This subpart should be easy to comply with.
Means of Egress
This subpart states that you must provide an unobstructed means of exit from any place in the office. OSHA requires you to place a map of the office with the exits, fire extinguishers, smoke detectors, fire alarm, and sprinkler systems located on the map. These should be placed in areas where the employee can easily view them in case evacuation of the facility is necessary. This subpart also requires you to create an emergency action plan for your office. This should include a fire prevention plan that lists any fire hazards in your office and provides training for employees on the fire hazard of materials located in the office. The emergency action plan also includes a list of any employee who has medical or first aid training, and the location of the first aid kit. Emergency evacuation directions should also be included. The scenarios should include in case of fire, chemical spill, and weather-related emergencies such as hurricanes, tornadoes, blizzards, and floods. One of the most important features that should be included is a meeting location in case the facility is evacuated so all employees can be accounted for. This subpart sometimes is neglected because people don’t think it will ever happen. However, when it does, you will be happy you have rules in place.
The requirement for the employer to provide hearing protection is based on the exposure time equal or in excess of an 8-hour time-weighted average of 85 decibels. This is a very rare situation in a dental office. The sound of a sander is measured at 85 decibels. Since we are rarely exposed to something that loud and should never be so exposed for an 8-hour period, this is not applicable to the dental office. Nevertheless, you should be aware of the requirements.
Fortunately, there are not many items that we use in a dental office that require ventilation, but there are some. In the lab, work with monomers can be very overwhelming. Also, if you grind many models, dust particles can be a problem. A ventilation hood or fan should be provided in this area. The darkroom is another place of importance: cleaning the processor ventilation is necessary. This is another good reason to go with digital x-rays to eliminate this concern. The last item is an autoclave that uses chemicals instead of steam to sterilize instruments. These should have filters attached if you continue their use. Because of this, steam sterilizers predominate the market today.
This pertains to radiation originating from radio stations, radar equipment, and any other source of electromagnetic radiation. This section does not apply to the dental office.
This applies to several items in the dental office. Bulk oxygen is one of them; if you have central nitrous available in your office, you must comply with storage regulations for the large tanks. Hazardous materials are another—check with your state regulations on disposal of certain items in your office. Examples include amalgam, developing solutions, and any other hazardous chemicals you may use in your office. Proper training of employees in handling and storage of these items is essential. Make sure you have procedures in place in case of any accidents involving these items, including proper protective wear and notification in case of spills.
Personal Protective Equipment (PPE)
In the dental office we consider the following items our PPE: warm-up jackets (long sleeved, high necked, fluid resistant), masks (high filtration), protective eyewear (must have side shields), and gloves (latex or nitrile for dental procedures, heavy duty gloves for cleaning). These items should be provided to the staff members in order to protect them from possible contamination from body fluids or chemicals. Warm-up jackets should be worn during dental or cleaning procedures only and changed daily or when penetrable blood is present. Jackets should not be worn in break rooms or out of the office. The employer is required to launder this item in the office or have it laundered by a professional service. This is the largest protective item we wear. It is also the most exposed. Keep this in mind when training employees about the exposure this item has received throughout the day. Safety glasses are another item that is extremely important but not always worn. Challenge those employees who choose not to wear provided safety glasses to wear them just 1 day and see all the material that accumulates on them. This should be an easy reminder of how important wearing this item is for their safety. The following is the proper sequence to put on and take off PPE:
Wearing PPE is one of the easiest ways we can prevent exposure. As an employer it is your obligation to train employees on the proper use of these items.
Medical and First Aid
Because we work in a healthcare facility, we usually think that much more is required in this area than is actually necessary. OSHA requires that you provide a basic first aid kit that includes bandages, a one-way valve for CPR, and a compression bandage. You must also provide an eyewash station for employees. This should be properly maintained by checking it on a monthly basis to make sure it is working correctly. Make sure everyone knows the location of the first aid kit and the proper use of the eyewash station. It is also a great idea to post important phone numbers such as those for the hospital, police, fire, and poison control. Also list the name and phone number of all staff members who have special training. Don’t forget to put the number and address of your facility on this list so it is easily found in case of an emergency.
Do you have a fire extinguisher? This should be the first question you ask yourself regarding this subpart. Many of the fire safety items were discussed in the Means of Egress s/>