Occupational Safety & Health Administration Guidelines for Dentistry

Transcription

1 Occupational Safety & Health Administration Guidelines for Dentistry Overview Overview Dr. Raghunath Puttaiah Plano, Texas, USA Website: Mobile site: 1

2 History of OSHA Regulations & Guidelines Occupational Safety & Health Act Initially passed in 1970 for every private sector employer Prior to this, each state had their own laws Later states developed their own OSHA regulations that were equal to or had higher standards than the federal acts that were approved by OSHA 2

3 Scope of OSHA Responsible for Employee Safety Does not cover Self-Employed persons Employee situations that are regulated by other federal rules Responsible for Enforcement of guidelines Assessment of non-compliance, fines and criminal charges 3

4 Scope of OSHA When certain situations are not addressed in the OSHA Rules The general duty clause is applied Where the employer provides employment in a safe environment free of recognized hazards that can cause harm, physical injury or death to the employee The employer should have mechanisms in place to reduce the risks or prevent injury/death to employees 4

5 Some common areas health professionals are CITED by OSHA Bloodborne Pathogens Hazard Communications PPE Eye Wash Protection Maintenance of Injury and Illness Log Electrical Systems Wiring General Complaints from employee 5

6 What happens when employee complains OSHA compliance health and safety officer will call or visit the facility Occur more frequently due to complaints than surprise or scheduled inspections The inspectors or officers look for Training of employee Documentation of training Exposure Control Plan Engineering & Work Practice Controls Hazard Communication, General Office Safety Complaints or dissatisfaction of Employee(s) Takes pictures of the facility or issue Collects evidence Statements by employer or employee 6

7 Who is at risk for Inspections? Only offices with employees Offices with many employees (Random) Offices that are corporations (Inc.) Employee Complains of Unsafe Conditions OSHA Inspects small offices only on employee complaint and focus on the particular issue as well as other safety issues When employer does not enforce regulations On regulated waste (within the office only) When the Dentist is an employee of a Incorporation (may be an owner himself). 7

8 What happens after an inspection? Conduct a Closing Conference Discuss alleged violations Attempt to obtain agreement concerning abatement List a date for abatement of alleged violations 8

9 What could an employer do for the inspection? Legal right to demand a Warrant Legal right to demand a subpoena for records Inspector not allowed to interfere with patient care Consult your attorney on the following-- OSHA inspections Legal obligations & regulations If inspection is refused by the employer If ongoing inspections need to be terminated 9

10 What could an employer do for the inspection? Employer may not admit to violations But take inspectors RECOMMENDATIONS under advisement Provide to employees or post a copy of OSHA citations Employer has 15 working days following the receipt of citation to file a notice of contest OSHA will grant an informal hearing during those 15 days & usually reduces fine, but rarely vacates citations 10

11 What are the OSHA regulations we need to understand? Bloodborne Pathogen Standards Hazard Communications Office and general safety Ergonomics Nitrous Oxide Safety 11

12 Bloodborne Pathogen Standards 12

13 OSHA Bloodborne Pathogen Standards Part-3: Bloodborne Pathogen Standard Final Rule 29 CFR published December 06,1991 Became effective March 06, 1992 Part IX 29 CFR 1910 Published January 18, 2001 (amendment to the existing Rule) 13

14 Scope Applies to all occupational exposure to blood and other potentially infectious material New rule covers needle less sharps and related devices stressing on the evaluation and possible adoption of the new devices and methods to reduce sharp injuries Include input from staff on selection and use Addition of evaluation or adoption of methods to control needle/sharp injuries into Exposure Control Plan 14

15 What is included as BBP Pathogens present in blood and that can transmit disease to employees or humans Other potentially infectious materials Saliva Teeth Biopsy specimen Serum sample Urine sample Items exposed to the above materials 15

16 Written Exposure Control Plan Includes Procedures for evaluating exposure incident or Exposure Determination Universal or Standard Precautions Procedures and means to control exposures Level of PPE, Engineering & Work Practice Controls, Universal/Standard Precautions, Training, etc. Means to ensure that the plan is understood by and accessible to employees The plan should be reviewed and updated at least annually or when tasks or procedures are changed This can be referred to as Standard Operating Procedures 16

17 Exposure Determination List all jobs which can expose all employees to BBP People exposed could include Dentist, hygienist, assistant, lab-tech, who come in contact with Blood and Other Potentially Infectious Material Also include Secretaries, receptionists, staff who may assist occasionally in patient care, clean-up etc. List of tasks & procedures for each category of employee with a potential for occupational exposure 17

18 Methods of Compliance Heart of the Exposure Control Plan Includes safe practices or practice methods to reduce the risk of exposures Whether Universal/Standard Precautions followed Use of appropriate level of PPE for a given procedure Engineering controls (HVE/SE; Rubber Dam; evacuation devices) Work-practice measures (Needle recapping; disposing needles in chair side sharps containers; placing instruments back in to cassette cradles to avoid sharps injuries) Housekeeping issues (Avoid leaving saturated waste or sharps in regular trash; differentiate between housekeeping and clinical tasks) Quality Assurance and Compliance is an essential and ongoing process (To be conducted at least annually if not more often; review procedures and protocols; correct or improve) 18

19 Engineering Controls Include HVE & Rubber Dam combination to reduce splash, spatter and aerosols Aerosol/Dust Evacuation Hood HVAC with laminar flow of air to reduce aerosols Rigid needle holders/syringe holders Safety devices on syringes Sharps Containers at chair side Examine and test Engineering Controls periodically 19

20 Work Practice Controls Handwashing & use of appropriate level of PPE Safe handling sharps or other potentially dangerous items Single handed recapping of needles Avoid overfilling sharps container Prohibit eating, drinking, smoking, application of cosmetics, handling contact lenses in clinical area 20

21 Work Practice Controls Safe Handling of Blood & Saliva Specimen Using leak free secondary containers Biohazard labeling of containers including secondary containers Decontaminating contaminated equipment before use or shipping Prohibiting mouth pipetting of BOPIM Labeling as Biohazard the contaminated equipment being shipped 21

22 Use of appropriate PPE Use of PPE to be procedure based PPE provided at no cost to employees Change of PPE as needed spelled out clearly PPE should be effective, NOT overtly permeable to blood and other body fluids Accessible to all employees of all sizes Training of Employees in use of PPE 22

23 Appropriate use of PPE..continued PPE can be Disposable (Singleuse-disposable) Reusable PPE must be decontaminated before re-use Mask, Eyewear, must be a combination Face shields must be combined with the use of masks to protect against splash/spatter 23

24 Appropriate use of PPE..continued Gowns, lab coats etc. used when in an occupational exposure situation Scrubs are not protective equipment Cover exposed skin (arms and chest) Protective equipment must not be worn outside the patient care area 24

25 Housekeeping Issues Work site should be clean and sanitary Written Schedule and instructions as what to clean with what to clean who should clean Can be contracted with a professional agency Inform of potential hazards 25

26 Decontamination to reduce exposures Work surfaces Equipment surfaces Clean bins, pails and cans periodically Safe handling of broken glass (use PPE & mechanical devices) Reprocessing of reusable sharps (instruments) Change of protective barriers in lieu of decontamination 26

27 What is Regulated Waste? Liquid or semi liquid BOPIM Items that would express BOPIM if compressed Items caked with blood or saliva Contaminated Sharps Pathologic and microbiologic wastes containing BOPIM or derived from BOPIM 27

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29 Sharps Containers Located as close as possible, and upright, Biohazard Not over filled, replaced ASAP Closed and lid secure while being moved Placed in secondary container if leaky or otherwise hazardous 29

30 Laundry Contaminated laundry is that which is soiled by blood or other potentially infectious materials Handled as little as possible Bagged on site immediately after use Not sorted or rinsed on site Bags labeled with Biohazard label or red bags Handled with gloves and other PPE as appropriate 30

31 Choices for handling laundry Single-Use-Disposables Outside professional laundry service Washer & dryer on site Unincorporated office owner can take laundry home One employee designated to handle (to be trained & documentation of training) Laundry Service 31

32 Labels Biohazard warning labels affixed to: Containers of regulated waste Refrigerators or freezers containing BOPIM Containers used to store or transport or ship BOPIM Any item that contains or has potential for containing BOPIM Ultrasonic Instrument Cleaner Suction pumps and filter casings 32

33 Label Design Fluorescent Orange with Biohazard Symbol and word Biohazard in a contrasting color Affixed as close to the container by string, wire or adhesive Red bags or containers may be substituted for labels 33

34 Medical Records Confidential medical record established For each employee Name and SS # of employee Copy of employee s HBV vaccination status including known dates of vaccination Ability to receive vaccination or refusal of vaccination 34

35 Hepatitis-B Vaccination Who: all employees When: within 10 working days Cost: employer Refusal: must sign refusal form Booster: not required in the U.S. Records: documentation of status required in the medical record 35

36 Hepatitis B Vaccination Additional Issues No prescreening required Provide copy of BBP Standard to Healthcare Professional who will administer the vaccine Post vaccination test not a must, but desirable Post-Exposure Evaluation and Follow-Up in the event of exposure Booster dose every five years not needed in the USA, not seroconversion noted among immunized persons 36

37 Definition of Exposure Incident Parenteral or non-intact skin contact with BOPIM, or parenteral contact with blood or other potentially infectious material Eye, mouth or mucous membrane contact with blood or other potentially infectious material BOPIM exposure through Sharps Injury or Splash/Spatter 37

38 Post Exposure Protocol Following two are a must Confidential medical examination Post-Exposure Evaluation and Follow-Up Must conform with current Health Information Portability & Accountability Act s requirements for both the Patient and Exposed Employee 38

39 The protocol Complete an exposure incident form Use of OSHA Injury and Illness log Identify Source Person Record infeasibility of identifying source person If the source person is identified Source tested for HBV and HIV after consent with refusal if any documented in writing Employee provided with source s test results Confidentiality of the source person s results/status explained to the exposed employee to avoid publicity or any other infringement of law 39

40 Injury and Illnes Log and & Bureau of Labor Statistics Log & Summary of Injuries and Illness Each employer must maintain this log for each establishment Entry to be made within 6 working days of injury or illness Log must be maintained for 5 years following end of calendar year of incident Access provided to employees, former employees and representatives Not needed for dental offices, may be necessary for large chains 40

41 Series of Events with the HCP in the event of exposure Copy of the BBP standard provided to the HCP Employee s job responsibilities with respect to occurrence of injury/incident Documentation of route of exposure and circumstances in which the exposure occurred Results of source persons blood test/status Employee s medical record that is maintained by the employer 41

42 Contract with HCPs Written contract with the evaluating healthcare professional to keep all records confidential Contact your LOCAL Infectious Disease Group and have a contract with them to handle this issue Medical center Box Clinic 42

43 What does the HCP do? Collect and test employee s blood after consent If blood collected but testing for HIV is refused by employee then blood preserved for 90 days Employee counseled & notified of all results Post-exposure prophylaxis provided per USPHS Counseling regardless of testing Illnesses evaluated that are reported by employee in the first 12 weeks irrespective of tests performed Healthcare professionals written opinion made available to the employer within 15 days after completing evaluation 43

44 HCP s report highlights Diagnosis and findings unrelated to exposure incident are not reported but held confidential Must contain: Whether HBV vaccine was indicated/received Employee informed of evaluation results Employee informed of any medical condition resulting from exposure, requiring additional evaluation and treatment 44

45 Flowchart of Post Exposure Evaluation & Follow-up Exposure incident occurs Employee reports incident to employer Employer sends employee to HCP with BBP Std., Job description, incident report (Form 101), patient s HBV & HIV status, employee s medical chart, HIPAA reqs. Healthcare Professional (HCP) evaluates Exposure Incident Arranges for Testing of Exposed Employee and Source Patient (if not known already) Notifies Employee of Results of All Testing Provides Counseling Provides Post-Exposure Prophylaxis, if necessary Evaluates Reported Illnesses (Items above are CONFIDENTIAL) Sends (Only) the HCP's Written Opinion to Employer Documentation that employee was informed of evaluation results and the need for any further follow-up; and Whether HBV vaccine was received Employee receives copy Of HCP s report Employer Receives HCP's Written Opinion & gives it to employee within 15 days 45

46 During PEP, Evaluation & Follow-up ALL COSTS BORNE BY EMPLOYER THE EMPLOYEE NEEDS TO BE ON PAYROLL 46

47 Record Keeping Medical record maintained for the duration of employment and 30 years beyond Available to employee upon request If dental practice is sold, Records transferred to new owner If dental practice is closed, Records offered to NIOSH 47

48 Training and Training Records Employees with occupational exposure must be provided training at no cost and during working hours Training at initial assignment, changes in tasks/procedures and annually Level of material must be appropriate in content and vocabulary of the employee Periodic Feedback from Employees and Review of procedures needed 48

49 Welcome! OSHA4Dental is focused on providing high-quality in-office Dental Safety Training to meet your compliance needs. We offer training in-- 1. Bloodborne Pathogen Standards 2. Hazard Communication 3. Building & Equipment Safety 4. Nitrous Oxide Safety Apart from Training & Documentation, we provide essential information on Infection Control and the CDC's Infection Control Guidelines on a CD/DVD for further use in the dental office for training of new employees Check out our website and download sample materials 49

50 Please Visit Or Call Dr. Puttaiah 50