1 OCCUPATIONAL HEALTH AND SAFETY IN THE DENTAL HYGIENE SETTING PRESENTED BY DR. DIANE REBRYNA, APRIL 24, 2014 Alberta Queen's Printer, 2011* - PERMISSION GRANTED FOR USE THE DENTIST S GUIDE TO OCCUPATIONAL HEALTH AND SAFETY RESPONSIBILITIES http://abdentists.com/wp-content/uploads/oct-4-ohs-manual-2012.pdf HANDBOOK OF OCCUPATIONALHAZARDS AND CONTROLS FOR DENTAL WORKERS http://employment.alberta.ca/documents/whs/ohs-wsa-handbook-dental-workers.pdf Alberta s OHS Legislation has three (3) parts: 1. Occupational Health and Safety (OHS) Act 2. Occupational Health and Safety (OHS) Regulation 3. Occupational Health and Safety (OHS) Code The ACT describes the obligations, rights and responsibilities of both Employers and Workers at the worksite. The Regulation and Code together state the rules applicable to OHS at Alberta workplaces. Occupational Health and Safety Code 2009 Explanation Guide OHS ACT stipulates responsibilities of BOTH Employers and Workers Employers must... for example (list not inclusive) : Identify hazards / Develop written Hazard Assessment Ensure safe working conditions Ensure safe equipment training, conditions and usage by Workers Ensure that Workers are trained in minimization of exposure to hazard and wearing of required PPE Ensure proper labelling and storage of chemicals (WHMIS) Ensure plans are in place for First Aid Services, as per OHS CODE Develop an Emergency Response Plan for the worksite, as per OHS CODE Workers must... for example (list not inclusive): Take reasonable care to protect themselves and other Workers Not perform work they are not competent to do (unless adequately supervised) Let the Employer know of conditions or equipment that are not safe Follow health and safety procedures at the workplace Participate in required training Wear required PPE Refuse to do any work that puts them or another Worker in Imminent Danger IMMINENT DANGER : No Worker shall carry out any work if they believe that there exists an imminent danger to the health or safety of that Worker: Imminent danger means a danger that is not normal for that occupation, or a danger under which a person engaged in that occupation would not normally carry out the person s work If a Worker refuses to carry out the work, s/he must notify the Employer (with documentation) of their refusal and reason... Employers have responsibilities if notified of an Imminent Danger : Investigation, Removal of Workers, Deal with the danger, and Develop documentation
2 VIOLATIONS The Act can force Employers and Workers to follow the rules. Violating the Act, the Regulation or the Code, or failing to follow an order given by an officer, may result in prosecution Conviction on a first offence can lead to a fine of up to $500,000 or a prison term of up to 6 months, or both Conviction on a second offence can result in a fine of up to $1,000,000 and/or a prison term up to 12 months HAZARD ASSESSMENT: A HAZARD is defined as any situation, condition or thing that may be dangerous to the safety or health of Workers Reference: OHS Code, Part 2 Employers must, according to Legislation Assess a work site Identify existing and potential hazards Prepare a written and dated Hazard Assessment involving input from Workers Make sure Workers are informed of the hazards and the methods used to control the hazard ADA+C Standards direct that a Written Hazard Assessment must be completed to identify the following risks/hazards in the Dental /Dental Hygiene Setting: Physical hazards Biological hazards Chemical hazards Radiation hazards It is also required that any Psycho - social Risks at workplace be assessed for Workers: Working conditions? danger nearby? Stress? Working alone? Fatigue? Workplace intimidation / bullying? Workplace location? isolated ADA+C Standards also state that Policies and Procedures must be in place for immediate response to Worker exposure to chemicals... Chemical Hazards are partially addressed by Review of MIs and Material Safety Data Sheet documentation Information must be available as required by WHMIS... Workplace Hazardous Materials Information System...(WHMIS): Protects the health and safety of Workers by promoting access to information on CHEMICAL hazardous materials used in the workplace Governed by federal and provincial laws and regulations Outlines responsibilities for suppliers, Workers and Employers Any person supplying or using controlled products must comply Requires proper labelling of controlled substances, updated MSDSs, and training programs with implementation of knowledge
3 DID YOU KNOW? Globally Harmonized System - GHS : The GHS is an international initiative to standardize chemical hazard communication globally http://www.ccohs.ca/oshanswers/chemicals/ghs.html GHS does not replace WHMIS What will change under GHS? Classification of Chemical Hazards Some new symbols: Some new classes of hazards e.g. explosion and aspiration Label requirements (M)SDSs Target date for GHS in Canada: Final regulations are expected to be published in the Canada Gazette Part II in 2014. Health Canada s goal is to have the updated WHMIS laws in force by 2015 or later. Employers will be expected to have updated their WHMIS program and training to include the alignment with GHS by June 2016 (exact timelines to be announced) How is a Hazard Assessment conducted in a Dental / Dental Hygiene Setting? Look around the Clinic- how is the work is done - what are the physical/ emotional challenges that DHCP face - how might they be hurt? Talk with fellow DHCP - what procedures might they consider unsafe? Consider what could go wrong (even if for years, it hasn t!) Look at all MIs for pieces of equipment regarding safe operating instructions ~ is equipment being used safely? Look at all MSDSs for safety considerations for chemicals and materials ~ are DHCP taking the necessary precautions Consider the possibility of workplace violence or impact of stress on DHCP NEED TO TALK? Consider the Canadian Dental Hygienists Association s (CDHA s) new Employee and Family Assistance Program (EFAP) An employee and family assistance program for CDHA members. This free, confidential counselling and wellness service for members and their eligible family members is provided through Homewood Human Solutions and offers a broad range of personal, work-related, health and family counselling services and resources over the phone or online. www.cdha.ca OHS states that wherever possible, hazards should be eliminated. If elimination of hazards is not possible, they must be controlled by use of (in order of preference)... 1. Engineering Controls: Eliminate the hazard or substitute it with something safer 2. Administrative Controls: Use safe work procedures (supported by policies) Established through training and supervision for Worker 3. Use of PPE: OR 4. Combination of the above (least desirable approach) NOTE: HOW Hazards are controlled must be documented Hazards Assessment must be an on going process... Re-evaluate anytime... New procedure is initiated New Workers are employed, OR A procedure is performed in a new part of the Dental / Dental Hygiene Clinic
4 IMMUNIZATIONS: ADA+C Standards direct that all DCHP must comply with immunizations required in a Dental Setting... A: RUBELLA (mandated under Public Health Act): Government has power to enforce Alberta Regulation 238/85 Public Health Act Communicable Diseases Regulation: Special Measures (5) directs that all staff of day care facilities and persons with face to face contact with patients in a health care facility shall ensure that they are immunized against Rubella Front end DHCP be assessed with records filed For assistance with obtaining past records re: MMR, contact your local public health unit. If born prior to 1970, DHCP used to be considered immune re: Rubella status, new guidelines are now in place: All healthcare workers must have 2 documented doses of MMR vaccine For information, contact: HC Worker / HC Student Assessment Program In Calgary: 403 955-9397 In Edmonton: 780 735-0100 (Immunization Business Unit) B. HEPATITIS B IMMUNIZATION: ADA+C Standards direct that all clinical DHCP and reprocessing personnel must be assessed regarding their immunity to Hepatitis B and provided Hepatitis B immunization if required Establish how assessment is done ( e.g. serological? evidence of records?) Establish who pays for assessment and boosters if required Follow guidance of public health Health Care Worker Program offers information regarding Hep B immunizations on a cost recovery basis: In Calgary: 403 955 9397 In Edmonton: 780 735-0100 (Immunization Business Unit) C. RECOMMENDED: Varicella, ANNUAL Influenza, and Tetanus Developing an Immunization Policy for a Dental / Dental Hygiene Clinic? Consider consultations with LEGAL and HR experts when developing this policy What immunizations are required e.g., as a condition of employment? Which DHCP is policy applicable to? Establish who tracks for renewal i.e., clinic HR or DHCP? What if a Worker refuses? What are grounds for exemption? NOTE: Immunization records/documents for DHCP must be retained in privacy protected files for personnel
5 FIRST AID PLAN: ADA+C Standards direct that A FIRST AID PLAN, EQUIPMENT AND SERVICES must be in place... Part 11 of OHS CODE (First Aid): Dental/Dental offices are medium hazard work environments. The Employer must ensure that first aid services, equipment, and supplies are available. The requirements are based on the following three factors: The type of work site The total number of Workers at the work site Proximity to a health care facility OHS Code lays out the required First Aid supplies The correct number of First - aiders must be available at all times training and valid certificates must be received from an approved agency (available on OHS website) Steps to consider when developing a First Aid Plan for a work site: Refer to OHS CODE to determine the degree of hazard of the worksite (Dental / Dental Hygiene Setting classified as MEDIUM Hazard) Refer to OHS CODE tables to determine the required services, equipment and supplies Establish emergency transportation for injured Workers from the work site to the nearest health care facility A Worker has a duty to report injury or illness to the Employer as soon as known Employers must develop records of injury that are kept for 3 years First Aid Records must be kept confidential (any information non-identifiable if released and Workers provided copies if requested) LATEX CONSIDERATIONS FOR DCHP: Standards directs that all DHCP must be aware of signs of possible latex adverse reactions and have a plan in place to deal with such reactions Possible Latex Adverse Reactions in DHCP range from: Irritant Contact Dermatitis to... Allergic contact dermatitis (type IV hypersensitivity) to... True Latex Allergy (type 1 hypersensitivity to latex proteins) National Institute Occupational Safety and Health (CDC / US) says: DHCP who are definitively diagnosed with an allergy to NRL (natural rubber latex) protein should: Avoid, as much as is feasible, subsequent exposure to the protein Take precautions at work (and outside the workplace) - use ONLY non - latex (nitrile or vinyl) gloves Ensure that all other DHCP in the Dental / Dental Hygiene Clinic use only non-latex gloves Use only synthetic rubber dams Seek medical advice - to determine if work restrictions are necessary All DHCP, whether sensitive or not, should minimize their exposure to NRL in the clinic: Use non-latex gloves (OR consider reduced protein powder free latex gloves) Frequently change ventilation filters and vacuum bags Check ventilation systems for adequacy for fresh or recirculating air Frequent cleaning of all work areas contaminated with latex dust Education of DHCP on signs and symptoms of latex allergies, AND Evaluate all products used in the Dental / Dental Hygiene Clinic. List below provides examples: Strong recommendation that policies and procedures are in place for management of latex adverse reactions in clients, not just DHCW.
6 ADA+C STANDARDS REQUIRE WRITTEN POLICIES THAT OUTLINE THE USE OF WORK PRACTICE CONTROLS FOR THE PREVENTION OF: 1. EXPOSURE TO BLOOD AND BODY FLUIDS AND CHEMICALS 2. INJURIES FROM SHARP OBJECTS (... includies projectiles) Work Practice Controls alter the manner in which a task is performed minimizing the risk of exposure: e.g. Needles remain capped prior to use Use of appropriate PPE during procedures that may cause injuries from sharp objects, projectiles or exposure to chemicals Work practice controls are developed and stressed through education and training of Workers with supportive clinic policies and procedures in place By contrast, Engineering controls act on the hazard itself (e.g. Safety engineered devices (SEDs)) Needle guards / Retractable needles Self sheathing injection needles Shielded burs on dental handpieces Required use of Safety Engineered Sharps as per Part 35 of OHS Code NOTE: the Dental environment is not exempt from use (July 2010) ADA+C BBP PROTOCOL / POST - EXPOSURE PROPHYLAXIS (PEP) Significant exposures must be dealt with immediately. These are: Percutaneous exposures, where skin of DHCP is punctured or scraped (parenteral) Blood and body fluid splashes (including saliva) into non-intact skin (dermatitis, cuts or abrasions) Blood or body fluid splashes (including saliva) onto the mucosa of eyes, mouth or nose Refer to ADA+C IPC Standards Appendix pages 48-51 for information regarding: Management of a Significant Exposure Form(s) to use for documentation requirements ** Remember to document First Aid that is administered - to meet OHS requirements Know what to do in advance of the occurrence of a Significant Exposure : Have your clinic protocols laminated and posted Ensure that all DHCP knows where the protocol is located in the clinic Know First Aid Steps that must be taken ~ First Aider will document treatment The IPC Officer for clinic will contact Health Link Alberta for advice and referral for PEP and post - injury counselling if necessary NB: POST HEALTH LINK ALBERTA NUMBER FOR YOUR AREA or call Toll-Free 1-866-408-5465 Complete appropriate documentation - where are forms located NOTE: Workers Compensation should also be contacted regarding the injury, if applicable
7 WRITTEN EMERGENCY PREPAREDNESS AND RESPONSE PLAN: Employers must develop this as required by Section 115 of OHS CODE: For any emergency that requires rescue or evacuation of Workers Clients must also be evacuated from a Dental / Dental Hygiene Clinic The plan establishes what the Employer must do until emergency services personnel arrive The plan must be developed by the Employer with the involvement of affected Workers All affected Workers must be aware of the plan and be familiar with the procedures Potential Emergencies that may require evacuation of Workers: Fire Explosion: e.g. gas leak Directed evacuation (Municipal) Industrial accident (e.g. chemical spill ) Structural failure Weather (e.g. tornado; flood water) Natural disaster (e.g. earthquake, bushfires ) Threat (e.g. bomb, military attack) Accident e.g. train or aviation ACCIDENT INVESTIGATION AND REPORTING: Employers must: Report serious incidents and fatalities to the Government of Alberta Workplace Health and Safety Report any other serious injury or accident that has the potential of causing serious injury to Workers Investigate incidents that cause injury or have the potential to cause a serious injury by calling Government of Alberta Workplace Health & Safety (WHS) at 1-866-415-8690 Investigation Incident Reports must be prepared Two of the events that might occur in a health care setting and that EMPLOYERS must report (according to Section 18(2) of the Alberta Occupational Health & Safety Act), are injuries or accidents that: Result in a death of Worker Cause a Worker to be admitted to hospital for more than two days To complete an OHS Program for a Dental / Dental Hygiene Clinic, also CONSIDER the following to MINIMIZE RISK: Complete a DHCP Workplace Health and Safety Orientation Form AT HIRING Keep Records of OHS Annual Training for DHCP Complete OHS Incident Reports - continued learning opportunities Abbreviations: ADA+C ALBERTA DENTAL ASSOCIATION AND COLLEGE CRDHA COLLEGE OF REGISTERED DENTAL HYGIENISTS OF ALBERTA DHCP DENTAL HEALTH CARE PERSONNEL GHS GLOBAL HARMONIZED SYSTEM MIs MANUFACTURER S (OR MANUFACTURERS ) INSTRUCTIONS MMR Combined MEASLES, MUMPS, RUBELLA (VACCINE) (M)SDS (MANUFACTURER S) SAFETY DATA SHEETS OHS OCCUPATIONAL HEALTH AND SAFETY PPE PERSONAL PROTECTIVE EQUIPMENT SDS SAFETY DATA SHEETS (PER GHS ) SEDs SAFETY ENGINEERED DEVICES WHMIS WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM