PROTECTING YOUR PRACTICE - What Your OSHA Manual Really Needs

Call it satire, but one of the many forms of entertainment that I have when giving an OSHA training to dental offices is asking the question, "May I see your OSHA book?"  For a lot of offices, the level of confusion over the faces of the dental team is pure entertainment.  Can you blame me?  It's an OSHA class, I have to find some creative ways to put a smile on my face during these topics. Knowing that I am not there for my own entertainment, together we work through the process of finding their OSHA book...or what remains of an OSHA book they have. 

Many times, I pull out the remnants of a book maybe from 1993 that the office has relied upon as their OSHA manual.   The serious part of this conversation with the office is if an OSHA inspector were to walk in, one of the first things they would ask for is that manual.  Below are some examples of what an OSHA manual actually looks like. 

Once we have completed step one and located their form of an OSHA manual, we assess whether or not we can update their current book or get a new one altogether.  Next, let's look at what needs to be inside the OSHA book. 

The Requirements

1. Bloodborne Pathogens Standard

This is the most frequently requested and referenced OSHA standard affecting medical and dental offices. Some basic requirements of the OSHA Bloodborne Pathogens standard include:

• A written exposure control plan, to be updated annually
• Use of universal precautions
• Consideration, implementation, and use of safer, engineered needles and sharps
• Use of engineering and work practice controls and appropriate personal protective equipment (gloves, face and eye protection, gowns)
• Hepatitis B vaccine provided to exposed employees at no cost
• Medical follow-up in the event of an “exposure incident”
• Use of labels or color-coding for items such as sharps disposal boxes and containers for regulated waste, contaminated laundry, and certain specimens.
• Employee training.
• Proper containment of all regulated waste

Important Notes: 

An actual setup tray in an office after a procedure that shows the risks associated with team members that are tasked to properly sterilize these instruments. 

In the print above, I referenced the OSHA.gov website.  It is important that the bloodborne pathogen section in your OSHA Book has a written exposure control plan.  That means that an office actually has to write in the book.  An OSHA inspector wants to see writing in the book that details a plan to prevent needle sticks, etc.  The reason they want to see the writing is that it shows that an office is actually trying to be compliant for that particular location.  They don't want you to purchase an OSHA book and put it away for 20 years.  They want you to customize it for your location and update it throughout the year as you add safer devices.   

A much safer form of processing instruments using cassettes and proper techniques. 

For example, let's say you made a change in sterilization processes from pouches to cassettes.  That change actually helped reduce your risk of a team member getting a needle stick.  That change needs to be reflected in your OSHA manual.  The last step is making sure that your office and any new employee is trained on the Bloodborne Pathogen yearly.  It is required by law that you obtain this yearly training.  The dental office will need to keep your training certificates for 3 years in your OSHA manual.  

       2. Hazard Communication Plan

The hazard communication standard is sometimes called the “employee right-to-know” standard. It requires employee access to hazard information. The basic requirements include:

• A written hazard communication program
• A list of hazardous chemicals (such as alcohol, disinfectants, anesthetic agents, sterilants, mercury) used or stored in the office
• A copy of the Safety Data Sheet (SDS) for each chemical (obtained from the manufacturer) used or stored in the office
• Employee training

Important Notes

Again, the above was an excerpt from the OSHA.gov website.  The section labeled Hazard Communication Plan contains sheets that will need to be properly filled out.  Your office will need to include items for most of the products that have an SDS Sheet.  We will discuss the SDS Sheets next.  Most of the products that will need to be on the hazard communication plan include most items a dental team uses to properly turn over a room for the next patient.  Disinfecting wipes, ultrasonic solutions, chemical sprays are some examples of the products that will need to be listed in the hazard communication plan.  It will also need to indicate where you use them such as in the operatory or in sterilization. 

3. SDS Sheets and the GHS (Globally Harmonized System)

Important - If your OSHA manual does not have a section entitled Globally Harmonized System (or GHS), your office will need to obtain the GHS insert to be compliant. 

The Hazard Communication Standard, revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical to downstream users to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format. This brief provides guidance to help workers who handle hazardous chemicals to become familiar with the format and understand the contents of the SDSs.

Important Notes

A dental office is required to have labels on any product that is put into a container that does not have its original packaging.  The new label is located to the right.  It contains:

• Product Identifier
• GHS Pictograms
• National Fire Protection Association
• Signal Word
• Precautionary Statements
• Supplier Identification

For example, when you put ultrasonic solution into an ultrasonic, your office will need to put one of these labels on the ultrasonic lid that properly labels the solution within that ultrasonic.   Other possible items that would need to be labeled include secondary spray bottles, alcohol containers, etc that do not have its proper container. 

Now that we have identified the OSHA manual and everything that is to be contained in it, lets conclude with this list of must haves:

• Have an OSHA Manual
• Training - shows that you have been trained every year (keep a record in the book for the past 3 years)
• Bloodborne Pathogen section
• Written Exposure Control Plan
• Hepatitis B vaccination available
• Hazard Communication Section
• Written hazard communication sheet that shows the chemicals within your office that could be hazardous to your dental team
• SDS Sheets
• OSHA / Federal Labor Posters / Global Harmonizing System Poster

A Couple of Hints

• Atlanta Dental Supply will provide a free storage and service of SDS Sheets if an account is on a Prime Advantage Plan. 
• An Atlanta Dental Rep will provide customized OSHA/HIPAA training directly to your office. 
• All OSHA/HIPAA products can be provided through Atlanta Dental Supply. 

Jacob Sigmon has worked with Atlanta Dental Supply for over 15 years.  He writes a series of blogs that help protect dental practices in order to prevent lawsuits and build thriving dental practices. 

He may be reached at jacobsigmon@atlantadental.com