ARE YOU IN COMPLIANCE?
OSHA's Hazard Communication Guidelines for compliance states: "Hazard communication will be a continuing program in your facility. Compliance with HCS is not a “one shot deal.” In order to have a successful program, you must assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule."
Every dental facility needs a Dental Infection Control Coordinator. At a minimum, this person should:
- have a basic understanding of microbiology
- have knowledge in modes of cross-contamination
- be aware of safety and infection prevention procedures
- be knowledgeable in government regulations, rules and recommendations: (Occupational Safety & Health Administration (OSHA), Bloodborne Pathogens Standard (BPS), Hazard Communication Standard (HCS), and Center for Disease
- know what products and equipment are required for patient and provider safety
- write and update policies and procedures: Exposure Control Plan, Hazard Communication Program, list of hazardous chemicals with a Safety Date Sheet
- establish a post-exposure system (name, address, phone number and travel directions) to the nearest healthcare facility. Have all employee documentation relevant to the treatment including employee's medical and vaccination records.
- make sure all employees are trained upon hiring in regard to chemicals, products and procedures with follow-ups on an annual basis.
- document and maintain all equipment such as autoclave, eyewash, etc.
In addition to these specific items, compliance officers also will be asking the following questions in assessing the adequacy of the program:
Hazard Communication Guidelines for Compliance U.S. Department of Labor Occupational Safety and Health Administration OSHA 3111 2000 (Reprinted)
- Does a list of the hazardous chemicals exist in each work area or at a central location? And, do all employees know where that location is?
- Are methods the employer will use to inform employees of the hazards of non- routine tasks outlined?
- Are employees informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas? (nitrous and oxygen)
- On multi-employer worksites, has the employer provided other employers with information about labeling systems and precautionary measures where the other employers have employees exposed to the initial employer’s chemicals?
- Is the written program made available to employees and their designated representatives?
Linda Kihs, CDA, EFDA, OMSA, MADAA