Compliance 101: Start with a Solid Foundation

Mary Beth O’Brien
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“It’s not enough that we do our best. Sometimes we have to do what’s required,” said Winston Churchill, prime minister of the United Kingdom during World War II. Churchill was highly respected both for his political career and for his wartime leadership.

Why was doing better than your best important to Churchill? Because during normal times, our best is acceptable. But in doing day-to-day tasks, sometimes we give a lot less than our best, doing only what’s necessary to get the job done and nothing more.

Today, we find ourselves in anything but typical times. Now we need to do extra and go beyond our best. Each of us needs to reach deep within ourselves to find the strength to do what is required. It will take mental strength, fortitude, discipline, finances, and education to do what is required in the COVID era.

Difficult as this seems, it has been done before and can be done again. Our frontline healthcare heroes have done it, and now it’s time for all of us to improve on our best.

As our healthcare systems faced the extreme challenges of the early days of the pandemic, they did so without policies and procedures in place. They had to test, confront, measure, and adjust protocols to accommodate the fight against our invisible opponent, a virus.

And it has only been with the concerted effort of a variety of agencies that we have been able to adjust in such extreme circumstances. They provide the science, research, data, measuring, and monitoring to generate the scientific best-evidence for protocols needed to battle any healthcare situation.

So, now phase II has come. Most dental offices are phasing back into practice, and it looks different. They have established new protocols and training. We must live with and embrace this reimagined dental experience since the health and safety of our patients and staff as well as the public is at stake.

Dental offices are currently challenged with new thinking, attitudes, and ways of working, making it a perfect time to analyze existing compliance programs holistically and shape them into what our new world needs to implement lasting change with respect to evidence-based best practices.

Now, let’s discuss how to create an unshakeable compliance foundation so your practice can thrive.

Begin with a Solid Foundation

The first program you should have in your dental practice is Occupational Safety and Health Administration (OSHA) compliance. OSHA protects all employees and requires employers to train all employees.

OSHA compliance needs to be reviewed annually, when you hire someone new, and if there is a change of procedure, product, or equipment in your office. If you can’t protect yourself and your staff, how can you protect your patients and the public?

OSHA has two main standards for dentistry, the Bloodborne Pathogens standard (29 CFR 1910.1030) and the Hazard Communication standard (29 CFR 1910.1200), also known as HAZCOM.

OSHA has mandates for general safety and administration as well. You are required to have a written OSHA program that is specific to your office, and you must train all employees to adhere to those rules.

Bloodborne Pathogen Standard

The Bloodborne Pathogens standard is the key standard for dentistry. Its key provision is the Exposure Control Plan, which entails the identification and explanation of exposures within your office.

OSHA requires employers to provide training to employees about the hazards associated with blood and other potentially infectious materials, chemical hazards, physical hazards, and environmental and waste management hazards specific to each office. Do an office analysis. How are you protecting employees from exposures to these various hazards? You also need to identify and explain Standard Precautions, Work Practice Controls, and Engineering Controls.

The Exposure Control portion of the Bloodborne Pathogens standard is what allows us to develop the Infection Control Plan for the office. The Centers for Disease Control and Prevention (CDC), the ADA, the Organization for Safety Asepsis and Prevention (OSAP), and other organizations have created checklists and other resources to assist you in the day-to-day tasks and standard operating procedures that should be in place for an efficient, effective, and measurable infection control program.    

Lastly, but very important, you need a written occupational exposure plan. This plan determines each employee’s risk for exposure, the policies and practices in place to prevent an incident, the management of an incident, and the medical evaluation, intervention, and follow-up steps that are in place should an occupational exposure occur.

Hazard Communication Standard

Chemicals are used in every dental office. Hazardous chemicals are regulated by OSHA, the Environmental Protection Agency, and your state and/or local environmental agencies. Identified hazards in your office should be stated in your exposure control plan under chemical hazards.

You also are required to have hard copies of safety data sheets for any hazardous material or products in your office. All offices are required to have access to instructions for use (IFUs) and manufacturers’ manuals to maintain compliance as well.

Tools like oneSOURCE offer updated and comprehensive databases of IFUs and manufacturers manuals needed to comply with oversight agencies such as OSHA, the CDC, the ADA, and more. The oneSOURCE platform includes IFUs for dental instruments, equipment, and consumables, offering facilities access to any resource needed to provide superior patient care. The oneSOURCE database boasts nearly 100,000 searchable catalog numbers for IFUs ranging from dental curing lights to dental headpieces and implants.

Administration and General Safety

OSHA regulations also focus on administration, with employee record keeping, training, and vaccination program protocols in writing. Also, the General Duty Clause requires employers to provide a clean, healthy, and safe environment in which to practice. 

There is no specific standard for general safety, but OSHA does outline mandatory expectations pertaining to office design, electrical concerns, evacuation systems, pump and filter system placement, and so on. Also, are exits and non-exits clearly labeled? Do you have a fire escape plan and designated safe meeting area.

OSHA is the primary agency involved in reducing the risk of physical injury. National codes such as those enacted by Building Officials & Code Administrators International (BOCA) and the National Fire Protection Association (NFPA) as well as additional state and local building codes also apply.

Government regulations and recommendations have been developed with your best interest in mind. Today, the ADA and CDC have put recommendations in place so dental practices can resume treatment. Yet all of these recommendations are just heightened protocols that should already be in place.

So, take this opportunity to look at your “best” with regard to your safety and health programs. Review the CDC Basic Expectations for Safe Care, and visit ada.org and osap.org for checklists. Regularly consult your state and local health departments for updates and information for requirements specific to your jurisdiction throughout the pandemic as well.

Ms. O’Brien is a oneSOURCE consultant and owner and president of Office-Based Surgery Consultant. She also is a registered dental hygienist with more than 20 years of experience instructing on OSHA regulatory requirements as an outreach trainer. An OSHA Authorized Outreach Trainer, ICP, and office-based surgical consultant, she consults with leading hospitals, clinics, and dental and healthcare practices around the United States to help develop standard operating procedures necessary to achieve optimal infection control and compliance programs mandated by federal, state, and local officials.

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