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Got OSHA? 6 Easy Steps to Office Safety Leslie Canham is sponsored in part by

The Ultimate Resource for Dental Education, Compliance & Regulations About Leslie Leslie Canham is a Certified and Registered Dental Assistant with over 40 years of experience in dentistry. She is an international speaker and has participated in numerous continuing dental education seminars. Leslie speaks to dental societies, associations, and study clubs. She is the moderator of the Infection Control Forum on Dentaltown.com. She is authorized by the Department of Labor as an OSHA Outreach Trainer in General Industry Standards. Her memberships include: The Organization for Safety, Asepsis and Prevention, The Speaking, Consulting Network, The Academy of Dental Management Consultants, the National Speakers Association, the California Dental Assistants and California Dental Association, and the California Association of Dental Assistant Teachers. Leslie is a registered provider of continuing education with the California Dental Board. Leslie is the founder of Leslie Canham & Associates providing dental professionals with: Mock Inspections In Office Training Tele-Consulting and Coaching Remote Training by Live Webinar Manuals and Training DVDs Online Home Study Courses and Webinars 8 Hour Infection Control Course for Unlicensed Dental Assistants P.O. Box 542 Copperopolis, CA 95228 Phone: 209-785-3903 Fax: 209-785-4458 email: Leslie@LeslieCanham.com Web: LeslieCanham.com

6 Easy Steps to Office Safety & OSHA Compliance 1. Training and Immunizations 2. Exposure Control 3. Chemical & Office Safety 4. Explain Labels, signs and symbols 5. Locate items in the office 6. Documentation and safety inspection Step 1 Training and Immunization Initial Training OSHA Bloodborne Pathogen Training Annually forms Medical & Hepatitis B Vaccinations Safe Work Conditions Written Injury and Illness Plans Prevention 1 2 Criminal Microbes & Desperate Office Germs HBV Cytomegalovirus Hepatitis B Hepatitis C Herpes simplex virus types 1 and 2 Human Immunodeficiency Virus (HIV) Mycobacterium tuberculosis Staphylcocci Streptococci Plus other viruses that colonize or infect the oral cavity and respiratory tract TB HIV Hepatitis B Vaccine Within 10 Days of employment 3 Vaccinations #1 Today #2 at month #3 at months Important Blood draw at 4-6 weeks after series to check for Hepatitis B surface antibodies (immunity). 4 Step 2 Exposure Control Exposure Determinations Schedule & Method of Implementation Hepatitis B vaccination and Post exposure follow up Communications of hazards Record keeping Work practice controls Engineering controls 5 Exposure Control Plan Exposure Determination means who is exposed to infectious agents? 1. Dentists 2. Assistants 3. Hygienists 4. Sterilization Assistants 5. Treatment Coordinators or Receptionists who help in the clinical area Schedule & Method of Implementation Means when do we Schedule? Annually in February What is our method of Implementation? We conduct training, offer HEP B Vaccine conduct office inspection 6 Page 1 2012 Leslie Canham & Associates, 209-785-3903 www.lesliecanham.com

Written Protocol for the Management of Injuries-Exposure Incidents OSHA defines an exposure incident as a specific incident involving contact with blood or other potentially infectious materials (OPIM) to the eye, mouth, other mucous membrane, non-intact skin, or parenteral under the skin (e.g. needlestick) that occurs during the performance of an employee s duties. When an exposure incident occurs, immediate action must be taken to assure compliance with the OSHA Bloodborne Pathogen Standard and to expedite medical treatment for the exposed employee. 1. Provide immediate care to the exposure site. Wash wounds and skin with soap and water. Flush mucous membranes with water. DO NOT USE Instrument involved on patient! Employee must report incident immediately to supervisor/employer 2. Determine risk associated with exposure by Type of fluid (e.g., blood, visibly bloody fluid, or other potentially infectious fluid or tissue). Type of exposure (e.g., percutaneous injury, mucous membranes or non-intact skin exposure, or bites resulting in blood exposure). 3. Evaluate exposure source Assess the risk of infection using available information. The source individual (patient) must be asked if they know their HBV, HBC, HIV status, if not known, will they consent to testing. 4. The exposed employee is referred as soon as possible * to a health care provider who will follow the current recommendations of the U.S. Public Health Service Centers for Disease Control and Prevention recommendations for testing, medical examination, prophylaxis and counseling procedures. Note ASAP* because certain interventions that may be indicated must be initiated promptly to be effective. The exposed employee may refuse any medical evaluation, testing, or follow-up recommendation. This refusal is documented. 5. Send all of the following with the exposed employee to the health care provider: A copy of the Bloodborne Pathogen Standard. A description of the exposed employee s duties as they relate to the exposure incident. (Accidental Bodily Fluid Exposure Form) Documentation of the route(s) of exposure and circumstances under which exposure occurred. (Accidental Bodily Fluid Exposure Form). All medical records relevant to the appropriate treatment of the employee including HBV vaccination status records and source individual s HBV/HCV/HIV status, if known. 6. Health Care Provider (HCP) Evaluates exposure incident. Arranges for testing of employee and source individual (if status not already known). Notifies employee of results of all testing. Provides counseling and post-exposure prophylaxis. Evaluates reported illnesses. HCP sends written opinion to employer: Documentation that employee was informed of evaluation results and the need for further follow-up. Whether Hepatitis B vaccine is indicated and if vaccine was received. 7. Employer Receives HCP s written opinion. Provides copy of HCP written opinion to employee (within 15 days of completed evaluation). Documents events on Employee Accident/Body Fluid Exposure and Follow- Up Form and Employee Medical Record Form. If the exposure incident involved a sharp, a Sharps Injury Log is completed within 14 days. Treat all blood test results for employee and source individual as confidential. Page 2

Exposure Incidents Have a Written Exposure Incident Plan First Aid Medical evaluation Accidental Bodily Fluid Report Form Sharps Injury Log Physician's written opinion form Follow up with Healthcare Provider if needed All testing results confidential Engineering Controls Engineered Sharps & Needle Recapping devices 7 2009 Leslie Canham 8 Work Practice Controls Altering the manner in which the task is performed Protective Eyewear Surgical Face Mask Clinical Jacket Gloves Provide Personal Protective Attire By prohibiting re-capping of needles with a Two-Handed Technique Employees May Not Take Contaminated Clinical Jackets Home 9 10 Step 3 Review: Chemical Safety Office Safety, Fire & Emergency Plans Communications of Hazards 1. Inventory all hazardous substances in the workplace 2. Maintain current Safety Data Sheets (formerly called MSDS) 3. Labels for containers not identified 4. Employee training on hazards and personal protective equipment 11 12 Page 3

HCS Pictograms and Hazards Health Hazard Flame Exclamation Mark Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non- Mandatory) Gas Cylinder Corrosion Exploding Bomb Gases Under Pressure Skin Corrosion/Burns Eye Damage Corrosive to Metals Explosives Self-Reactives Organic Peroxides Flame Over Circle Environment (Non-Mandatory) Skull and Crossbones Oxidizers Aquatic Toxicity Acute Toxicity (fatal or toxic) Page 4

Office Safety Work Areas, Aisles, Hallways free of trip and fall hazards First Aid Kit Exits Marked & Accessible Fire Extinguisher charged and visible Eyewash station working Ergonomics Step 4 Explain the meaning of Labels Signs Symbols Color-coding 14 Step 5 Locate items in your office with the Find It! checklist Step 6 Make sure documentation is complete Employee Training Records (Keep 3 yrs) Medical and Hepatitis B forms (Keep duration of employment plus 30 years) Inspect Office (Note areas that need to be brought into compliance) Employees fill out medical record keeping form Include Hep B documentation Dentists keep 30 plus years 15 Page 5

Step 5: Locate these items in your office Find It! Checklist Item Location Emergency Phone Numbers First Aid Kit Emergency Medical Kit Oxygen Tank Blood-pressure monitoring device Eyewash Station Fire Extinguishers Fire Alarm Floor plan for evacuation All Exits of office Main water shut-off for office Main gas shut off for office Main Electric breaker Material Safety Data Sheets (MSDS Book) Office OSHA Manual Bloodborne Pathogen Standard (Hint: in OSHA Manual) Exposure Incident Manual Standard Operating Procedure Manuals Employment Posters Locate Signs or Symbols for: Radiation Laser in use Biohazard Location Where All Hazardous Chemicals Are Stored Chemical Spill Kit Pharmaceutical Waste container Sharps Container Biohazard Waste Container Amalgam Recycle Container Lead Foil Recycle Container Location Of Personal Protective Attire: Mask Exam Gloves Utility Gloves Protective Eyewear Face Shield Clinical Jacket Where to Place Contaminated Laundry Page 6

Step 6: Complete all recordkeeping forms including training documentation and conduct your own safety inspection OSHA TRAINING CHECKLIST Use this checklist to help familiarize employees with your OSHA safety plans. Offer Hepatitis B Vaccination (HBV) within 10 days of employment. 1) If the employee has already received the Hepatitis B Vaccination, the employer must obtain documentation of results. 2) If the employee declines the offer of vaccination, the employee must sign a Declination of Hepatitis B Vaccination form. Employee fills out the Medical Record form. Give the employee a tour of the office, citing the following locations; 1) Eyewash station (show employee proper use procedures) 2) Locations of fire extinguishers, electrical breaker, emergency exits, and the meeting spot in the event of an emergency evacuation of the office 3) Location of OSHA manual and MSDS books 4) Where employee may obtain a copy of the Bloodborne Pathogen Standard 1 5) Location of Personal Protective Equipment and instructions for proper use 6) Location of first aid kit and patient emergency medical kit 7) Location of required employment posters 8) Areas where hazardous materials are used/kept (Explain signs, labels, and/or color coding) Explain the appropriate actions to take and persons to contact in the event of an exposure incident involving blood or other potentially infectious material, including the method of reporting the incident and the medical follow-up that will be made available. Have the employee read the following safety plans in your OSHA manual; 1) Injury & Illness Prevention 2) Exposure Control 3) Hazard Communication 4) Ergonomics 5) Fire, Emergency & General Office Safety I,, have received and understand the Employee Print Name above information. I agree to comply with the safety and health procedures and policies required by the office. Employee Signature Page 7

Employee Medical Recordkeeping Form Name: Social Security No: Employee Address: City: State: Zip: Job Title: Employment Start Date: Termination Date: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Immunity & Vaccinations: Dates By Copy of Bloodborne Pathogens Administered Whom? Standard given to provider? Yes/ No HBV Vaccine: Anti-HBs test: ( ) Declined vaccine. (See Informed Refusal for HBV Vaccine at bottom of page-employee must sign) ( ) Vaccine unnecessary. Employee has no exposure potential. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ History of Exposure Incidents: Date & Brief Checklist for Follow Incident Report Source Individual Name of Explanation Up Completed? Completed? Tested? Source Individual Yes/ No Yes/ No Yes/ No ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Results of Medical Follow-Up Procedures for Exposure Incident: Written opinion of Refusal of Care physician obtained? Care Completion Date or Testing Yes/No Date ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ If Employee Declines Hepatitis B Vaccination this Informed Refusal for Hepatitis B Vaccination Must Be Signed I understand that due to my occupational exposure to blood or other potentially infectious material (OPIM), I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine at no charge. However, I decline the hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If I continue to have occupational exposure to blood or OPIM and wish to be vaccinated with hepatitis B vaccine in the future, I can receive the vaccination series at no charge. Employee signature: Date: Maintain this record for duration of employment plus 30 years. Page 8

DENTAL OFFICE INSPECTION Office: Date: Inspected by: Yes No GENERAL SAFETY & HEALTH Does facility have employee medical records on all employees? Including records or declinations of Hepatitis B vaccinations? Are new employees with risk of bloodborne pathogen exposure trained prior to assignment? Does facility have documentation of above training records of new employees? Employee work areas adequately lighted? Adequate ventilation in employee work areas? Are compressed gas containers securely fastened in an upright position? Are empty and unused compressed gas cylinders capped and properly labeled? All exits properly marked? Doors that could be mistaken for an exit properly marked? Exits and exit paths clear of obstruction, both inside and outside? Are all exit doors unlocked so emergency egress does not require keys? Are employees aware of the fire and emergency plan(s)? Do employees know the location of fire extinguishers and how to use them? Is the inspection tag current? Does location of fire extinguisher need a sign? Is there an eyewash station? Is it in good working condition? Does sign designate its location? Are all storage areas clean and orderly? Are articles stored on shelves stored so they can t fall on employees? Are areas under sinks and trash areas clean and orderly? Are machines and equipment in good working order with adequate safety guards? Electrical cords in good condition? Have grounded outlets/cords been bypassed or modified? Circuit breakers properly marked? Do employees know location of Emergency Medical Kit? Are any medications expired? Is there a First Aid kit for employees? Page 9

HAZARD COMMUNICATIONS Yes No _ e Saf ta She (SDS) being main ned correc? _ Do you have an products used, including injectable pharmaceuticals? _ Are all containers labeled so contents and hazards are properly identified? _ Are labels on secondary containers readable? _ Is the Master List of Hazardous Chemicals set up and maintained? _ Are chemicals stored properly? _ Have employees been trained on your Hazard Communications plan? _ Do employees know where MSDS information is kept andd how to read an MSDS? Comments: BLOODBORNE PATHOGENS Yes No _ Is the written Exposure Control plan up-to-date? _ Have all employees and tasks at risk of exposure been identified in the plan? _ Have all employees at risk been offered the Hepatitis B vaccinations? _ Is appropriate Personal Protective Equipment (PPE) provided? _ Are employees aware of the location of PPE? _ Is the laundry policy in compliance with OSHA requirements? _ Have employees received annual training on bloodborne pathogens and how to comply with the facility s plans to reduce the risk of infection? _ Does the training include modes of transmission of bloodborne pathogens and the symptoms of HIV and Hepatitis? _ Employees aware of the concept of Universal Precautions? _ Employees aware of the office policy for an exposure incident? _ Work areas orderly and easy to clean and disinfect if necessary? _ All biohazardous containers/are eas labeled? _ Are food or drink stored in areas where they could be contaminated? Aerosol Transmissible Diseases (ATDs) _ If required by your state, have employees received training on ATDs re: screening patients and are written plans in place? See CDC Guidelines www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm for screening patients for M. tuberculosis s a model f screening forr ATDs. Page 10

BIOHAZARDOUS WASTE Yes No _ Is the written plan based on current State and Federal regulations? _ Sharps waste disposed of at point-of-origin locations? _ Any sharp containers over-filled? _ All bags/containe rs properly labeled? _ Licensed waste transporter receipts/manifests kept on filee (required by current state regulations)? _ Is the area under the biohazard waste container non-absorbent? _ Area maintained in a clean and orderly manner? _ Employees been trained on the facilities biohazardous waste plan? _ Does facility have a contingency plan in case of biohazardous waste spills? _ Are employees aware of it? Comments: INFECTION CONTROL Yes No _ Appropriate disinfectant used for disinfecting surfaces? Instruments sterilized or disinfected according to CDC and/or state requirements? Is biological monitoring performed weekly to ensure eachh autoclave orr other mechanical sterilize is functioning properly? DENTAL BOARD, STATE, AND FEDERAL POSTING REQUIREMENTS Yes No _ Names of licensed dental healthcare providers posted if required by state dental board? _ Posted Infection Control Standards/Duties and Settings if required by state dental board? _ State and Federall employment posters and notices present? RECOMMENDATIONS: Page 11

Organize Your Own OSHA Safety Meeting The Basic Elements of an OSHA Annual Bloodborne Pathogen Program According to OSHA, the bloodborne pathogen training must contain the following elements: 1. A written copy and explanation of the Bloodborne Pathogen Standard. 2. A general explanation of the epidemiology and symptoms of bloodborne diseases. 3. An explanation of the modes of transmission of bloodborne pathogens. 4. An explanation of the employer's exposure control plan and the means by which the employee can obtain a copy of the written plan. 5. An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and Other Potentially Infectious Material (OPIM). 6. 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. 7. Information on the types, proper use, location, removal, handling, decontamination and disposal of Personal Protective Equipment (PPE). 8. An explanation of the basis for selection of personal protective equipment. 9. 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. 10. Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM. 11. 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. 12. Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident. 13. An explanation of the signs and labels and/or color coding to communicate hazards to employees. 14. An opportunity for interactive questions and answers with the person conducting the training session. Page 12

Resources Got OSHA? 6 Easy Steps to Office Safety \ Federal Regulations & State Plans www.osha.gov Centers for Disease Control Guidelines for Infection Control in Dental Health-Care Settings 2003 www.cdc.gov/oralhealth/infectioncontrol/guidelines/index.htm OSHA Manuals American Dental Association Regulatory Compliance Manual www.ada.org Build your own using OSHA model plans www.osha.gov/publications/osha3186.pdf OSHA Bloodborne Pathogen Standard http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10051 OSHA Hazard Communication Standard http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099 OSHA Posters http://www.osha.gov/pls/publications/publication.athruz?ptype=types&pid=5 Post Exposure Evaluation Protocol CDC Post Exposure Protocol http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5011a1.htm HIV Post Exposure www.cdc.gov/mmwr/preview/mmwrhtml/rr5409a1.htm CDC National Clinicians Hotline 888-448-4911 Personal Protective Equipment (Face and Eye protection) www.osha.gov/sltc/etools/eyeandface/index.html Evacuation Plans and Procedures www.osha.gov/sltc/etools/evacuation/index.html List of Chemical Disinfectants/Sterilants www.epa.gov/oppad001/chemregindex.htm Other OSHA and Infection Control Training Resources: Leslie Canham OSHA Training System DVD and Workbook www.lesliecanham.com OSAP www.osap.org From Policy to Practice: OSAP s Guide to the Guidelines Workbook Interactive Guide to the to CDC Guidelines select Ask Lily Video If Saliva Were Red US Air Force Power point training programs www.airforcemedicine.afms.mil/decs Page 13