The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
Episode #3 OSHA's Engineering and Work Practice Controls for COVID-19 Safety in Dentistry
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This podcast focuses on OSHA’s requirements for engineering controls and work practice controls. OSHA requires employers to provide a workplace free from recognized hazards that are causing or likely to cause death or serious physical harm. Assessing the workplace hazards and engineering controls and work practice and implementing controls are mandatory.
Welcome. I'm Leslie Cannum. I'm Mary Gavoni. I'm Linda Harvey.
SPEAKER_00I'm Olivia Juan. And together we are the Compliance Divas. Welcome to the Compliance Divas podcast. We bring clarity and simplicity to compliance by navigating the regulatory compliance to keep you on course. My name is Olivia Juan, and I'll be your moderator today. I have fellow Divas with me, Leslie Canham, Mary Gavoni, and Linda Harvey. Today we are discussing OSHA's requirements of engineering controls and work practice controls. OSHA requires employers to provide a workplace free from recognized hazards that are causing or likely to cause death or serious physical harm. We refer to this as the hazard assessment. To meet this obligation, it is important for employers to assess occupational hazards which workers may be exposed to. Work practice controls change the way a task is performed. Engineering controls remove the hazardous condition by placing a barrier between the worker and the hazard or having a strategy designed to protect the worker. Let's talk to our divas. Mary, would you give us a greater explanation of engineering controls and maybe give our listeners some examples of some bloodborne pathogen standard recommendations?
SPEAKER_01Thanks, Olivia. As you said, engineering controls are means of isolating or removing a potentially infectious disease exposure from the workplace under the bloodborne pathogen standard. So it means things like using Sharps containers so that we don't throw needles, contaminated needles in the trash and somebody can get exposed. Perhaps using a needle recapping device to prevent needle sticks when syringes are being recapped. Having any kind of a barrier between a healthcare worker and that infectious disease risk is an engineering control. Something that you use, you add into your protocols that you're following when you're doing procedures.
SPEAKER_00Great information, Mary. And I think that will help our listeners to put some key things into place for their safety. Linda, can you help us today to learn more about work practice controls and give our listeners some examples of what they can do for bloodborne pathogens standard?
SPEAKER_02Happy to do so, Olivia. When you think about work practice controls and engineering controls, they can overlap a bit. The work practice controls are typically more the techniques or controls that are behavior oriented. So while there are engineering controls that are implemented, such as having sharps containers in place, it's the actual behavior of using the sharp's container properly and not recapping needles with two hands and so forth. It also includes other areas such as, you know, making sure you wash your hands thoroughly, whether using sanitizer or soap and water. The bloodborne pathogen standard does require employers to have hand washing facilities, but now it's our duty to follow those CDC recommendations and make sure that we're sanitizing our hands with soap water or sanitizer at the appropriate time. So it's actually the behavior. And that can be challenging at times because we all know how crazy busy a dental schedule can be. So it's a matter of making sure that you follow through those processes and stay mindful of the steps all along the way. It reminds me of a situation when you think about sometimes we get uh we forget something, you know, we we've gone somewhere and we've forgotten our keys, or we think we didn't turn off the stove or lock the front door. And sometimes we get focused on that end task. What's the end goal? And the end goal is to say get the operatory set up for the next patient. But we sometimes can miss those steps, those behavioral steps along the way that actually keep us safe and maintain a safe workplace also for our patients.
SPEAKER_00Thank you, Linda. I love how you described it as behavior-oriented. That's excellent information. Leslie, can you give us an example of engineering controls as it relates to aerosol, especially in light of the fact that we're still in this pandemic?
SPEAKER_03Absolutely, Olivia. You know, originally when we first went into the pandemic, uh, many dental practices thought that they needed to have what was called an airborne infection isolation room. And this is similar to what hospitals have for patients who, for example, have active infectious TB, tuberculosis. And uh, as time has gone on in this pandemic, we found that it isn't necessarily a requirement for dental practices to have this high level of airborne infection isolation, because there are other strategies that we can implement as engineering controls. And one engineering control would be involved with uh ventilation systems. And that's probably our best defense is making sure that uh ventilation systems provide air movement in a clean to less clean flow direction for treatment rooms in a dental office. Uh, other uh engineering controls uh at ShareSight include, for example, the high velocity evacuator. And then there are other things that you can do with regards to having a high velocity evacuator, such as skilled use of a high velocity evacuator. I remember when I first started as a dental assistant, that was one of the skills that I really had to work on. At first, I was uh I was uh evacuating and I'd be sucking up cheeks and tongue, and the water level would continue to rise in the patient's mouth. But as soon as I learned how to really place that evacuator tip properly in the patient's mouth, most of everything that was generated during patient care was scooped right on up the evacuation system. And on top of that, not only having skilled use of that high velocity evacuator, but proper maintenance of the vacuum system itself is extremely important to make sure that you have maximum suck.
SPEAKER_00Thank you, Leslie. You actually brought back memories of my early days working as a dental assistant and training chair side. Uh so thank you for reminding me of those days. I appreciate that. Mary, can you give us some examples of work practice controls in aerosol environment?
SPEAKER_01Oh, thanks, Olivia. I'm I'm reliving the dental assisting days as well. I remember when my doctor that I worked for bought me a tipadilly adapter that didn't suck up the tongues and cheeks and the and the um sublingual mucosa, and it made my life so much easier. So I love Linda's um description of work practice controls for bloodborne pathogens about behavioral modifications, because that's something that's been very impactful during the pandemic in um preventing COVID-19 transmissions, is changing behaviors. In other words, um, hygienists who didn't use HVE before then had to adapt to a new way of um scaling, um, especially if they were going to use an ultrasonic scaler. But one of the work practice controls that was implemented early on was not using ultrasonic scalars, going back to hand scaling to prevent aerosols. And some practices opted not even to polish with a slow speed handpiece. But things like screening employees for symptoms and temperatures, screening patients for symptoms and taking temperatures, work practice controls, behavioral things that we do, which, by the way, are still in effect in the CDC guidance during the pandemic, that has not been changed. And the practice of wearing different types of PPE, transitioning from wearing a face mask and safety glasses to wearing a respirator and a face shield. So different behaviors, different things that we've been doing to help contain the aerosols.
SPEAKER_00Thank you, Mary, for that information. And I wanted to emphasize how important it is to conduct that hazard assessment. Anytime as a consultant that I have dealt with OSHA and an investigation of a dental office, the official will actually look at that hazard assessment. So it's important for our listeners who serve in the capacity as a safety coordinator to assess those hazards and write it down on that uh template or tool that you're using, what the hazard is and what you're doing to overcome that hazard. So, for example, Mary, what you were talking about, if there's an aerosol hazard, then what are the engineering controls that are in place? Do you have some of these safety devices, such as HEPA filtration, then you can add that in, or external suction, or whatever devices that you have supplemented into your program, and even the personal protective equipment that is being used? And at this time, I would like to get some closing remarks from our divas. Uh Leslie, do you have anything to add to our program?
SPEAKER_03Yes, Olivia. Uh, I do have a couple of uh final points that I wanted to make on the engineering controls with regards to aerosols. And what we are looking at uh with our changes since COVID hit the scene, uh a lot of federal offices have uh purchased equipment to help with aerosol management. In some cases, uh it is uh an expense or an investment. They have uh extra oral uh evacuators, chair side evacuators that that uh capture aerosols that might escape the high velocity evacuator resection or even the saliva ejector. And uh that's not something that is listed in the CDC recommendations, but something that is listed is the uh air purifiers. And air purifiers have really made a huge improvement in dental practices. Um, I actually uh purchased an air purifier for my own house because of the difference that it makes in reducing the contaminants in the air, the spore and the mold and pollens and things like that that we get that are naturally occurring in our environment. But what I'm finding in these dental offices that are getting the portable high-efficiency uh air purifier or HEPA filters, that they have these on while patient treatment is going on. And I find that the extra added bonus for dental practices is that the practices don't smell like dental practices anymore. It seems to eliminate the odors that I used to detect when I'd walk into a reception room of a dental practice. Many times I would smell that strong disinfectant odor. Or if they were using something that, uh like in a temporary cement, uh zinc, a zinc oxide and eugenol, or or for uh you know, root canals, they were using maybe a PCMP for pulbotomies. And and that was an overwhelming medicinal smell, which I think sometimes frightens patients when they walk in the door, brings back memories of of uh perhaps not so pleasant dental visits.
SPEAKER_00Thank you, Leslie. As you were speaking, I was thinking about years ago when I worked as a uh dental assistant and office manager, standing in the line at the grocery store, and the person behind me said, Ew, you smell like the dentist office. So I could well remember working in uh the high concentrations of chemicals and how we actually took that odor home with us. So very interesting. Linda, do you have anything to supplement to our podcast?
SPEAKER_02Well, Olivia, I'd like to mention one other work practice control, and that is um it's very important. It's not eating, drinking, smoking, uh, applying cosmetics, lip balm, or uh fiddling, if you will, with your contact lenses in any areas where there's potential exposure to blood and other potentially infectious materials. And while we know that the overwhelming majority of dental professionals don't smoke, and I especially don't smoke in the office, there are other things that we might be prone to, behaviors that we might be prone to, not just in the operatory, but also in the lab and in sterilization. When an office is very small, there's not adequate space for a staff break room, and staff wants to put their snacks or drinks or something nearby, then we have to be very careful because those are the types of work practice controls that are not allowed under the blood worm pathogen standard and could uh create uh exposure events and also could lead to OSHA fines if the practice had an unannounced inspection.
SPEAKER_00Great tips, Linda. Thank you. Mary, can you give us some more information?
SPEAKER_01Yes. If we have listeners who are wondering where they start with a hazard assessment if they haven't done it, the American Dental Association has created a number of templates on their COVID-19 site that can help you to put together a hazard assessment in your practice. But make sure that you don't just download the forms from the ADA and use them without really carefully reviewing them to make sure that they reflect what you are or are not doing in your practice. Those things are always very helpful. And also if you need some guidance, you can go to the OSHA website, OSHA.gov, and you can look for uh uh some guidance for dental settings. And we will actually put that resource on our website, the compliancedevas.com, so you can download that. You don't have to go searching for it. And um, that may also give you some guidance on how to do a hazard assessment. And as Olivia said, make sure that you have it in writing because if you do have an OSHA inspection, then if you haven't documented it in writing, OSHA will assume that you haven't done it. And the other thing we want to do is make sure that you always stay up to date on CDC guidance. Many people are dropping some of the CDC recommendations about patient screening and so forth. And those may change in the future, but they haven't yet. So make sure that you check in frequently on the CDC website, cdc.gov, and see what's happening there, see what's current for healthcare settings.
SPEAKER_00Thank you, Mary.
SPEAKER_03And Leslie, do you have something to add? You know, as I was listening to everyone talk, uh, we missed talking about a couple of things that are both um engineering controls and work practice controls uh for COVID. One, and in engineering control, we've seen these plastic barriers or sneeze shields pop up everywhere. And in dental offices, I'm seeing them. I'm hoping that we will continue with uh keeping them in place. They look very nice. They really don't separate the the appearance of the receptionist or front desk personnel uh from the uh reception room visitor. And they also do provide that extra layer of uh splash field, if you will, between someone sneezing or coughing and what might get to the worker at the front desk. So the barriers not only at the front desk, but one dental practice that I visited that had an open base style seating put barriers between their chairs in the way it's very similar to a hospital room where you have that curtain where it's attached to the ceiling, it's longer than a shower curtain, but it's the same idea. And that helps to prevent some of the spatter and droplets from going from one person to another. And then with regards to work practice controls, and that's something that you do that's different than uh physical engineering control, uh, that many dental practices have stopped allowing uh visitors to their operative area. So uh in some cases it's necessary, such as pediatric or uh maybe patients that have special needs or uh need assistance from a caregiver or a spouse when they have their dental treatment performed. But I like the idea of keeping people out of the treatment room that aren't there to receive treatment or aren't there to deliver the treatment.
SPEAKER_00Oh, I love that. Thank you so much, Leslie. And I wanted to bring up that a couple months ago we had a matter that came up where there was an allegation of a complaint of not dealing with aerosol properly in a dental practice. And when OSHA evaluated their records and conducted a walkthrough, their hazard assessment was in excellent shape. And they listed all the engineering controls and work practice controls in place to deal with aerosol, and there were no violations discovered and there was no citations issued. So that's really the goal is to stay in compliance and promote safety for our team as well as our patients. So we really appreciate you tuning in to the compliance divas, and we hope that you will follow us on our next podcast. We bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please submit your questions to support at the compliancedivas.com. And as Mary mentioned, we will have the resources and citations listed for you, and we are happy to share any further information that you may need. Thank you for tuning in.