OSHA Update 06

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OSHA Update 06

• Nicholas J. Grimaudo, DMD MS MS
• University of Florida

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Introduction

• Compliance with the law and with OSHA standards
  are important factors in every dental/medical
  practice.
• Every employer must develop and maintain written
  plans that provide policies, procedures, and
  practices for the employee.
• Effective plans work to prevent work related
  injuries and illnesses.

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Written Plans

• OSHA requires that affected employers write and
  implement the following plans
• Emergency Action
• Fire Safety
• General Safety
• Hazard Communication
• Bloodborne Pathogens Exposure Control

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Examples of Office Safety Documents and Records

• Regulatory Documents
• OSHA bloodborne pathogens standard
• OSHA hazard communication standard
• State, local, or other regulatory documents that
  may apply

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Examples of Office Safety Documents and Records

• Policy Documents
• OSHA written exposure control plan
• OSHA written hazard communication plan
• Written (or oral) emergencies and fire plans
• Other state/local policies not covered by OSHA
• OSHA poster (form 2203)

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Examples of Office Safety Documents and Records

• Training records
• OSHA form 300
• OSHA form 300A
• OSHA form 301
• OSHA employee medical records (confidential)
• Hepatitis B vaccination declination form
• Written report from physician on vaccination of
  employees
• Exposure incident report

• Written report from physician on post-exposure
  medical evaluation and follow-up
• Sterilizer spore-testing results
• Radiographic equipment certification
• Fire extinguisher certification
• MSDSs
• Hazardous chemical inventory

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Emergency Action Plan

• The purpose of this plan is to eliminate or
  minimize hazards to employees in the event of a
  fire or other emergency. Employers with 10 or
  more employees must have written plans. Employers
  with fewer than 10 employees may have oral plans.
• The written emergency action plan outlines
  employer and employee actions to ensure safety
  during fire and other emergencies. The plan is
  kept at the workplace and is available for
  employee review.

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Emergency Action Plan

• The plan must include the following information
• Emergency escape procedures and route
  assignments.
• Procedures for employees who remain behind to
  perform critical operations.
• Procedures to account for all employees after
  emergency evacuation
• Identification of employee rescue and medical
  duties.
• A means of reporting fires and other emergencies.
• Types of evacuation to be used in emergency
  circumstances.
• Names and job titles of persons who can be
  contacted for further information about the
  emergency action plan.

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Emergency Action Plan

• Emergency telephone numbers must be posted near
  telephones or other conspicuous locations.
• Before initiating the plan the employer must
  identify and train designated employees who will
  assist in the action plan.
• The plan is reviewed and changed as needed.

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Fire Safety Plan

• OSHA requires that employers provide proper
  exits, fire-fighting equipment, emergency plans,
  and employee training to prevent fire deaths and
  injuries in the work place.
• During OSHA inspections employee compliance with
  safety standards is evaluated. A written plan is
  necessary for employers with 10 or more
  employees.
• An oral plan may be utilized for fewer than 10
  employees.

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Fire Safety Plan

• This plan should include
• Building fire exit inspections
• Portable fire extinguishers rules
• Emergency evacuation plan procedures
• Fire prevention plan procedures
• Fire suppression plan procedures

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Fire Safety Plan

• Each workplace building must have at least two
  means of escape remote from each other to be used
  in fire emergency.
• Fire doors must not be locked or blocked.
• Exit routes must be clear and free of
  obstructions and properly marked.

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• Only approved fire extinguishers are permitted
  and must be kept in proper working condition.
• Portable fire extinguishers must be inspected
  annually by an outside fire extinguisher company.

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General Safety Plan

• All employees are required to follow safety
  policies and rules.
• Employees may need to customize their plan to fit
  specific circumstances.
• Employee noncompliance should be included under a
  disciplinary policy statement.
• The general safety plan is not designed as a
  substitute for specific plans that are required
  by OSHA.

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General Safety Plan

• The plan should include the following
• General company policies
• Basic personal protective equipment
• General safety rules
• Sample office safety rules
• Accident reporting rules
• General first aid practices
• Safety responsibilities of supervisors
• Disciplinary policy statement
• Sample disciplinary policy

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Hazard Communication Plan

• The purpose of the hazard communication standard
  is to ensure that the hazards of all chemicals
  produced or imported are made known.
• This Right to Know law covers information
  concerning hazards in the workplace, and must be
  transmitted to employers and employees.
• Employers must develop and maintain a hazard
  communication plan.
• This plan must be in writing. Employers must
  inform employees of this plan.

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Hazard Communication Plan

• The plan must include the following
• Container labeling
• Employee training
• Material Safety Data Sheets (MSDSs)
• Other forms of warning

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Hazard Assessment Plan

• OSHA requires employers to assess their workplace
  to determine if any actual or potential hazards
  require the use of personal protective equipment
  (PPE).
• Regulations require that the employer identify
  hazards and verify the assessment in writing.
• OSHA requires employers to first eliminate or
  reduce hazards through engineering controls and
  work practice controls before using PPE.

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Material Safety Data Sheets (MSDSs)

• Failure to maintain information about hazardous
  chemicals is one of the most common violations of
  OSHA standards.
• A MSDS must accompany every hazardous chemical
  that a manufacturer or importer of that chemical
  ships.
• It is the primary document in the Hazard
  Communication Standard (HCS) issued by OSHA.
• Manufacturers of hazardous substances may use any
  form they want as long as all pertinent OSHA
  information is included.

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MSDSs contents

• Product Information
• Chemical name as it appears on the container
  label
• Name, address, and telephone number of the
  company that makes the chemical
• Hazardous Ingredients
• List of hazardous parts of the chemical
• Chemical identified by common and scientific
  names
• Hazardous ingredient or percent of principle
  ingredients

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MSDSs contents

• Exposure limits set by OSHA/other
  organizations-maximum exposure based on an eight
  hour day
• Permissible Exposure Limits (PEL)
• Threshold Limit Value (TLV)- set by the American
  Conference of
• Governmental Industrial Hygienists (ACGIH)
• Short Time Exposure Limits (STEL)- 15 minutes
• Immediate Danger to Life and Health (IDLH)

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MSDSs contents

• Physical/Chemical Characteristics
• Melting Point temp at which solid turns to
  liquid
• Boiling Point temp at which liquid changes to
  gas
• Evaporation Rate the higher the number the
  faster it evaporates
• Specific gravity density compared to water
• Vapor Density compared to air
• Vapor Pressure volatility

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MSDSs contents

• Fire and Explosion Hazard Data
• Flash Point the lower the point, the more
  dangerous the material
• Upper Explosion Limits (UEL)
• Lower Explosion Limits (LEL)
• Between these limit a substance is likely to
  ignite

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MSDSs contents

• Reactivity Data
• By-products chemical could generate
• Hazards if chemical decomposes
• Health Hazard Data
• Inhalation or breathing
• Ingestion or swallowing
• Direct skin contact
• Acute effect
• Chronic effect

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MSDSs contents

• Symptoms of Exposure
• Precautions for Safe Handling and Use
• Handling under normal conditions
• Handling a spill
• Cleaning up a spill
• Need for immediate evacuation
• Disposing of waste chemical
• Control Measures
• Ventilation
• Respiratory protection

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Sample Hazard Communication Plan

• This plan should include
• Container labeling procedures
• MSDSs
• Employee information and training guidelines
• Sample forms to be used as part of the plan
• Employers Covered - every employer that uses a
  hazardous material is covered

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Sample Hazard Communication Plan

• Recent OSHA Directive
• Under an OSHA directive issued in March 1998,
  employers may provide employee access to MSDSs
  through an alternative system, including use of
  the Internet, microfiche, computers, CD-ROM, and
  fax machines.

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Sample Hazard Communication Plan

• Recent OSHA Directive
• Employers using these alternative electronic
  means must ensure all of the following
• Reliable devices in the workplace are available
  at all times to access the MSDSs
• Worker training in use of the devices, including
  use of software
• An adequate back-up system for rapid access to
  MSDSs. In medical emergencies, employers must be
  able to immediately provide copies of MSDSs to
  medical personnel.

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MSDS requirements

• A current master inventory list of all MSDSs will
  be maintained
• The chemical name or identity used on each MSDS
  will be the same as that used on the container
  label
• The chemical and common name of all ingredients
  determined to present a hazard will appear on all
  MSDSs

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MSDS requirements

• When revised MSDSs are received, the following
  procedures will be used to replace old MSDSs
• MSDSs will be readily available to all employees
  during each work shift using the following
  procedures
• Note If an alternative to paper copies of MSDSs
  is used, describe this system in the blank space
  above.

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Reporting, Recordkeeping, and Posting

• OSHA has revised its recordkeeping regulations as
  of January 18, 2001 to become effective January
  1, 2002.
• Many employers found recordkeeping cumbersome and
  new forms were created to simplify requirements.
• OSHA forms 300, 300A, and 301 will replace OSHA
  200 and 101.

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Reporting, Recordkeeping, and Posting

• OSHA No. 300 replaces No. 200-a Log of
  Work-Related Injuries and Illnesses.
• This log is used to record the occurrence,
  extent, and outcome of cases recorded during the
  year.
• It must be posted between February 1st and March
  1st of every year.

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Reporting, Recordkeeping, and Posting

• OSHA No. 300A is a separate Summary of Work
  Related Injuries and Illnesses revised to make it
  easier to calculate.
• OSHA No. 301 replaces No. 101-an Injury and
  Illness Incident Report that includes more data
  about how the injury or illness occurred.

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Reporting, Recordkeeping, and Posting

• These forms are not required to be submitted to
  OSHA, but must be available for inspection.
• Dental employers with fewer than eleven employees
  must prepare a report of the exposure incident,
  but are not required to complete the OSHA forms,
  300, 300A and 301.

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Posting Requirements

• Employers must display in a prominent place an
  OSHA poster that explains employees rights under
  OSHA regulations.
• This poster must be displayed even if the
  employer is exempt from OSHA record keeping
  requirements.
• If an employer is subject to OSHA record keeping
  requirements, an annual OSHA 300A summary log
  must be displayed showing work-related injuries
  and illnesses.

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Posting Requirements

• OSHA citations, even if they are being contested,
  must be posted either for three working days or
  until the hazard is corrected, whichever is
  longer.
• The citation should be posted at or near each
  place on alleged violation occurred.

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OSHA Training

• Practicing infection control procedures, managing
  hazardous materials, and regulated medical waste,
  and ensuring safety against fire and storms are
  collectively referred to as office safety.
• Training plays a critical role in most safety
  programs.
• The most common cause of employee injuries is
  unsafe work practices.

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OSHA Training

• Therefore, the employer must identify the
  training needs of employees, design learning
  activities, and monitor the training to make sure
  it is effective.
• The office safety aspects of dentistry are
  expanding rapidly, with new and revised
  regulations and recommendations appearing
  frequently.

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OSHA Training

• New concepts and approaches along with new
  products and equipment continue to bring better
  control for the spread of disease.
• Management of the office safety and training
  program presents majorchallenges to ensure
  compliance and effectiveness

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OSHA Training

• Continually review infection control, hazardous
  materials, and other office safety regulations
• Prepare, review, and update the office exposure
  control plan, infection control procedures
  manual, hazardcommunication program, and other
  safety procedures for the office

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OSHA Training

• Develop protocols that provide step-by-step
  procedures to be followed in practicing office
  safety
• Provide new and continuing team members with
  initial and updated training on all office safety
  policies and procedures
• Assure that the janitorial staff receives proper
  training related to personal protection during
  office cleaning procedures

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OSHA Training

• Monitor compliance with office safety procedures
  and related regulations
• Organize the manage procedures for hepatitis
  vaccination of new team members and procedures
• Postexposure medical evaluation and follow-up
• Review circumstances surrounding exposure
  incidents

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OSHA Training

• Evaluate, select, and maintain the stock of
  products and equipment needed to accomplish
  office safety
• Assure proper maintenance, availability,
  cleaning, and disposal of personal protective
  equipment and all other items needed for office
  safety
• Perform spore-testing of office sterilizers
• Manage disposal of regulated medical waste

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OSHA Training

• Check equipment for decontamination and label
  contamination portions before shipping for repair
• Organize and maintain material safety data
  sheets, proper labeling, the inventory list, and
  proper storage for all hazardous chemicals in the
  office
• Maintain smoke alarms and extinguishers and
  monitor electrical cords and connections

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OSHA Training

• Keep exit doors and evacuation routes clear and
  assure other compliance with local fire safety
  codes
• Maintain certification of radiographic equipment
• Maintain appropriate documents and records

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OSHA Training

• Assure that all members of the dental team have
  constant opportunity to voice concerns about and
  suggest improvements in office safety
• Communicate with patients regarding safety
  procedures practices in the office

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Training Documentation

• OSHA generally requires employers to document
  their training efforts and to provide all
  materials for any required training program to
  OSHA on request.
• Specific training regulations usually require
  employers to keep training materials for at least
  the duration of a workers employment, if not
  longer.

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Certification

• OSHA sometimes requires a certification to
  establish training.
• A certification is a written documentation
  verifying that the employee understands the
  training and can apply it in the workplace.
• The specific area for which certification would
  apply to dentistry is for personal protective
  equipment.

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Certification

• Blood borne pathogens and hazard communication
  both require training annually.
• Hazard training is also necessary whenever a new
  hazard is introduced in the work area.
• PPE training is required upon initial assignment.

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Hazardous Communication Training

• Training and information on hazardous chemicals
  in the workplace musttake place at the initial
  assignment and whenever a new hazard is
  introduced.
• Certification is not required.

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Hazardous Communication Training

• Hazard training must cover the following
• Requirements of the Hazardous Communications
  Standard
• Work areas where hazardous chemicals are present
• Location of written Hazardous Communication Plan
• Location of Biohazardous Waste Management Plan
• Methods to detect hazardous chemicals in the work
  area
• Methods for protection from chemical hazards,
  work practices, emergency procedures, and
  protective equipment
• How to use MSDSs

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State and Federal Standards

• To gain OSHAs approval, states must enforce
  standards that are at least as effective as the
  federal rules.
• States with approved plans can have standards
  that are stricter than OSHAs, but not less
  strict.
• States must also modify their own standards to
  keep current with federal changes.

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State and Federal Standards

• Whenever federal OSHA adopts a new standard,
  states must adopt a comparable standard within
  six months.
• Several states such as California, Michigan,
  Oregon, and Washington do have plans that vary
  widely from the federal provisions.
• Although federal OSHA does not apply to public
  employees, most state plans do so.

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State and Federal Standards

• Two states, Connecticut and New York, have
  OSHA-approved plans that apply exclusively to
  public employees.
• Regardless of how closely a particular states
  plan follows federal OSHA, an employer located in
  a state with an OSHA approved plan should contact
  its state agency to pinpoint specific standards
  in which it is interested to ensure compliance.

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Finished