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 #44 OSHA-Required Emergency Action Plans & Procedures
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Welcome. I'm Leslie Cannon. I'm Mary Gavoni.
SPEAKER_03I'm Linda Harvey. I'm Olivia Juan. And together we are the Compliance Divas. Imagine this. You're at work, your cell phone goes off with an emergency announcement that a tornado has been spotted. What will you do? Recently, tornadoes ravaged western Kentucky, killing at least 80 people. Eight people died at work, where they worked at a candle factory, and six died at an Amazon factory in Illinois. Were they forced to stay at work? What would you do if your dental office had this announcement? My name is Olivia Juan, and I'm your moderator for today's timely podcast on the subject of evacuation plans and procedures. These recent natural disasters, such as tornadoes and fires, make us think of what we would do? Are you prepared? What are the minimum elements of an OSHA compliant emergency evacuation plan? Welcome to the Compliance Divas podcast. We bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please subscribe to the Compliance Divas podcast. Resources we mention may be found at thecompliancedivas.com. Submit any of your questions to support at thecompliancedivas.com. Let's get some input from our fellow divas. Mary, we would love to get some information from you and have you describe shelter in place and how dental practices must consider employee safety as well as their patients.
SPEAKER_02Thanks, Olivia. You are so right. Those tragedies that happened in the Midwest recently, and not even in tornado season, just really bring up all kinds of questions about are we prepared? And so just like a dental practice should have an emergency medical incident plan for their practice so that they can be prepared if a patient or if an employee has a medical emergency, we need to have a plan for some type of an outside emergency. My first question would be: how would you know if there was an emergency? Do you have a TV on in the office? Is there a radio station on? Would you get information from the internet? Or what about cell phone alerts? Many communities have an emergency notification network. And so every practice should find out from their city or county how they could sign up for that so they would get alerts if it's weather or if it's an active shooter or some kind of a situation. Could be a train derailment where there's a chemical release. You just don't know what kind of disasters could happen. And some of it depends on perhaps what kind of industry is in the area where your practice is. So shelter in place really depends on circumstances. Whether you should evacuate your facility or find a safe place to ride out perhaps what the emergency is. Obviously, if there's a fire, you are not going to shelter in place, you are going to evacuate. But if there is a storm occurring or there's been some kind of a chemical release, then sheltering in place means you stay in a safe place in your facility. You might even need to block off air vents and so forth. If the air is contaminated outside, so your two key things would be is there debris in the air or have local authorities said that the air is highly contaminated and you shouldn't be outdoors. And if the air is contaminated, you should turn off your HVAC system and as best you can cover the vents in your facility with plastic trash bags and duct tape. So that would be part of emergency supplies, trash bags and duct tape. Then you need to designate and have a prepared shelter in place location. So if it's uh a tornado or severe weather that's um occurring in your area where you want to be is in an interior room above ground that is away from outside windows and walls. If you can, if you have a basement or a lower level in your facility, certainly go there. Um and you want to make sure that wherever that designated shelter is, that you have some emergency supplies, certainly water, bottled water, and perhaps even some non-perishable food, like granola bars, for example, something that doesn't go bad, because you are responsible not only for all the employees in your facility, you are responsible for patients. And if you have a patient, for example, that maybe has a blood sugar disorder, they have hyper or hypoglycemia, you want to have something that can support them in case they have an emergency. And then you look at having things like battery-powered radios, extra batteries, flashlights, first aid supplies, and again, trash bags and duct tape if you need to secure air vents and so forth. And you need to make sure that all the employees understand the difference between an evacuation order and a shelter-in-place order. Do you have a code that you use? Or if you have a large facility, how are you going to notify everyone what they're supposed to do? So hopefully that's helpful information. And the key things there are plan ahead, know what to do, because panic will set in in the case of that kind of an emergency.
SPEAKER_03Really good information, Mary. Thank you for that explanation. Linda, can you elaborate on how dental offices should prepare and how to report an emergency?
SPEAKER_01Absolutely, Olivia. I think when we consider how to report an emergency, it would be helpful if our listeners thought about that from a twofold process. One is how do we alert the doctor and the team something's going on? Because depending upon the size of the practice and how it's built and the, you know, hallways and corridors, it may be rather large office. And then how to notify the proper authorities. So when you think about within the office, everybody on the team needs to know how to alert each other when there's some kind of emergency going on. And so depending upon the size of the office, they may be able to be very informal. And I'm thinking of offices whereby you step outside your operatory and you can pretty much see the whole office to your left and to your right. You know, it's just a small practice. And at that point, they may be able to just call out and say, Help, you know, my patients faded, or fire in the break room. That may work. But when you get into larger offices, especially inside large office buildings, or it's a big standalone building itself, we have to have a more formal process in place. And that might be a pager on the telephone system. And many offices that become the larger size offices are wearing headsets. So that's another ideal way to communicate with one another when there's some kind of emergency. Either way, we want to consider. I think our listeners could consider using a paging system or coding system, Olivia, to let our team members know what kind of emergency it is. And I think about that from the perspective when I worked in corporate health care, we had an 11-story building that was all of our organization. It was a pediatric specialty group. And on different floors, we had our emergency medical bags. So our process was to call our internal switchboard operators, notify them what the emergency was, whether it's a child or an adult, and then they subsequently paged Dr. Blue, which was our code for code blue. There was somebody who had a medical emergency, and it was pediatric Dr. Blue, if it was a child who was in distress. So whoever was closest to the bags at that time, the healthcare providers on the floor, different floors, would grab the emergency bag and go to the scene. So that's a more formal process for a very large organization. So pairing that back to a dental practice, it would depend upon the size of the practice, how they would like to be comfortable notifying one another. But the main thing is to be sure everybody is alerted, even individuals that have stepped out back to take out the trash or they're in the restroom. And then secondarily, the next step in the process is how do you report an emergency to the authorities? Well, the first thing we think of is we're going to pick up the phone and call 911, right? But we want to communicate who's in charge of that. Just as we learned every or continue to learn every two years when we renew our CPR, you know, when if you're the person who sees an individual go down, then you turn and you point to somebody and you designate them to call 911. So having a process like that is very important. I and you want to have some backup people named, probably, because if you say, Sally, you're the person that's always going to call 911. Sally may be out sick when this happens. She may be out gathering lunch for everybody, or she may not be working there anymore. So we have to consider you're not naming just one person, but having it designated by locations in the office, for example. So whoever is designated to make that emergency call needs to know the office address and/or floor number if the office is located in a large building, Olivia. Um, let's consider the fact that it could be a new employee or maybe a visitor that calls 911. That was the case for myself last summer when I was on site with a smaller size office. I was down the main hallway from the reception area, was two hygiene operatories and then the break room. And back in the break room where I was situated, I could hear somebody hollering at the front desk. And my first thought was, well, there's an unhappy patient here. I guess they're having to wait, you know, or they don't like their bill. But come to find out, that person was alerting somebody else in the office at the receptionist had fainted and she was on the floor. This was a pregnant young lady who had some medical challenges, I think, and she just probably didn't eat breakfast or whatnot. And she's on the floor. So I ended up calling 911. But thankfully, knowing enough about dental practices like we do, I could grab the business card and I knew what to do at that point. But having that nearby is important because it just goes to remind us that during an emergency, oftentimes we're not thinking clearly. And while you may have worked in an office for a long time and you know that I just like the back of your hand, you we can forget it in an emergency. So I would recommend to our listeners that they post a business card on or near each phone. Have some non-emergency numbers too, such as just an ambulance transport. So if there's a trip and fall and somebody doesn't need emergency care but needs a transport to the hospital or an urgent care, you have that number handy, as well as the non-urgent number for the police. So overall, I think those are two ways that our listeners can look at it, Olivia. Just, you know, notifying doctor and team member that something's going on, and then how to notify the authority. And then I know I will probably talk about this in a few minutes, but having the plan, developing your plan and practicing your plan is very important to be sure everybody's communicating effectively.
SPEAKER_03Good tips, Linda. Thank you. I love how you explained how you worked in a facility that had uh special codes to report an emergency. How helpful is that? Leslie, we would love for you to discuss how dental offices should develop and implement an emergency action plan.
SPEAKER_00Well, thank you, Olivia. There's actually four essential steps for an emergency action plan. First is development of the action plan. Second, as Linda described, authority, you know, pointing someone to lead and coordinate the plan or appointing somebody to take certain tasks like calling 911. Uh, the third is employee training and plan review. And then fourth is also plan review, coordination, and update. And I'm going to take a just a minute to elaborate on each one of these four steps. So, development of an emergency action plan. A very simple plan suffices for most dental offices because there's really few hazardous materials and hazardous uh, like, for example, um oxygen tanks or nitrous, things like that. There's there's not uh peppered throughout the practice. Usually things are pretty well uh located in one location. So um what we want to do is make sure that employees know that they must evacuate when an alarm sounds. And it can be either a fire alarm, it can be a public address system. For example, for those that live in the coastal areas, they may be worried about tsunamis or flooding. Um, and there's a great e-tool on the OSHA website to help a dental practice develop their own personalized emergency action plan. I love this tool because you simply fill in the blanks and then print out your personalized emergency action plan. And filling in the blanks, this actually helps with another OSHA requirement that the emergency action plan be site specific with respect to emergency conditions. So, for example, in San Francisco, they have a lot of uh earthquakes. And in California in general, we also have uh wildfires sometimes. So we have to take into consideration what kind of hazards occur in our area. And then we also need to make sure that we have evaluated evacuation policies, procedures, emergency reporting mechanisms, um, alarm systems that that's the case as well. There's also on the OSHA website a great emergency action plan checklist that you can print out. And this actually helps you think a little bit more about how to develop your plan. So once you develop it, you review it with employees, make sure everyone knows what to do before, during, and after an emergency, and always keep a copy of your emergency action plan in a convenient location where employees can get to it. Also, it's a good idea to provide a copy of it to employees. You can communicate if you have a smaller practice of 10 or fewer, you can communicate your emergency action plan orally. I recommend having it in writing because whenever I travel to different states outside of California to conduct OSHA training, I always contact the OSHA local office and speak directly to the OSHA safety officer that visits dental offices. And time and time again, I have heard them say that the number one thing that they cite dental practices on is not having an emergency action plan. So I'd recommend having that in writing. As Linda mentioned, and part number two, authority, appointing someone to lead and coordinate your emergency action plan and evacuation. And it's pretty critical that if you have a larger dental practice, that employees know who that coordinator is and understand that this person has the authority to make decisions during an emergency. Now, that might very well, for our clients, be the dentist. And also, uh, when emergency officials, such as like local fire department uh or other emergency services personnel respond to your dental practice, they'll assume responsibility for the safety of the building occupants. They now have the authority to make decisions regarding evacuation or what other uh other actions are necessary to protect life and property. The third essential step for an emergency action plan, of course, is employee training. And just like with OSHA bloodborne pathogen training, we need to make sure that each and every person understands what the plan is when they're first hired with the practice. So if you don't have an emergency action plan, we want to get together all of the prior things I mentioned of having a plan in writing and appointing somebody with authority and then conducting training and making sure that everyone understands how to assist in the safe and orderly uh emergency evacuation of employees. You should review that not only when employees are initially onboarded with your practice, but also uh at least on an annual basis. And if somebody has uh responsibilities with regards to emergency training, perhaps they have a new role. If that changes, then they need to have training again, which aligns with our bloodborne pathogen training. When things, when there's new hazards, we need to train employees. So effective training does call for uh frequent training, meaning at least on an annual basis. And I always recommend including drills in which employees can actually practice evacuating their workplace and gathering in an assembly area. I uh one time actually brought to the my OSHA training a teddy bear, and and I threw the teddy bear on the ground. Nobody knew what I was doing. And I said, that is a patient who just passed out. What are you gonna do? And I asked people around the room to describe the steps that they would take. And then I said, the teddy bear is now your doctor. So the person that's in charge of your emergency action plan, the person that's supposed to have all the answers, is on the ground. Now, what are you gonna do? So having drills, even a fire drill, is important to make sure that everybody understands they're educated on not only the types of emergencies that could occur in your practice, but the proper course of action. Now, um, the fourth part of the emergency action plan is to make sure that you plan, review, have coordination and update. Once you've completed your action plan, review it carefully with employees, post it in an area where employees will have access to it. The employer must review with each employee upon initial assignment, as I mentioned before, about the emergency action plan plus fire prevention, and that the employee must know how to protect him or herself in the event of an emergency. And uh if you rely on assistance from local emergency responders, such as the fire department or local hazmat or other responders, you might find it helpful to review and coordinate your emergency plan with these organizations to ensure that you're aware of what capabilities uh outside responders have and what that they know what you expect of them. So operations and personnel change frequently, and an outdated plan will be of little use in an emergency. It's really important to review the contents of your emergency plan regularly and update it whenever those plans change or responsibilities change, or there's a change in the layout or design of a facility, or you have new equipment or new hazardous materials or processes that might affect evacuation routes or types of hazards. So the most common outdated item in emergency action plans is uh the facility and contact information. So uh placing consider placing important contact information on a separate page and put it in front of your emergency action plan so that part can be easily updated. And Olivia, I think that the OSHA website has each one of these items that I talked about, each one of these steps, and elaborates on it in great detail so that it's easy for anybody to understand how to put together an emergency action plan.
SPEAKER_03Thank you, Leslie. Such good information. And to emphasize what you had said is that if there are 10 or more employees, it has to be in writing. If it's less than 10, as you emphasized, it's not required to have it in writing, but it's still a really good idea. So there's no misunderstandings on how to deal with an emergency. Mary, I'd like to circle back around to you for you to briefly discuss fight or flee options. What does that mean?
SPEAKER_02Thanks, Olivia. Um, fight or flee really pertains to a situation where there's a fire in a practice. And I, Leslie, thank you so much for mentioning that fabulous e-tool that OSHA has about um putting together uh an emergency evacuation plan because on that site, and that resource will be um on our website for the podcast, there are just a tremendous number of resources to understand what OSHA's looking for from an employee safety standpoint. It's very practical information. A lot of the information that I talked about earlier about shelter in place is on that particular website and so forth. And one of the things that that OSHA says is that, of course. The main reason why employment settings need to be evacuated typically is a fire. And so you need to have a plan for what to do. Some people say, well, we have a fire extinguisher, and so we'll just fight it with the fire extinguisher. Just know that OSHA has very specific information about portable fire extinguishers, that they need to be mounted on the wall and they need to be tested and so forth. But if your policy would be that you were going to fight the fire with a fire extinguisher, then you need to make sure that the person who's designated to do that understands when it's appropriate, what type of fire, how to use that fire extinguisher. And then OSHA further talks about doing a risk assessment. How would you know whether you should use a fire extinguisher or evacuate? So, four questions that OSHA suggests. One, is the fire too big to try to put it out? Is the air safe to breathe? And keep in mind that in many cases, when a facility is burning, there are a lot of toxic fumes that are released from materials that are burning or melting as a result of the fire. Is the environment too hot or smoky? So is it dangerous to stay in the facility to fight the fire with a fire extinguisher? And is there a safe evacuation path? So if you have a safe evacuation path, then you need to get out. The majority of dental practices are in smaller facilities where it might be easier to evacuate. But as Linda mentioned earlier, she was in a multi-story building. So how do we know? And we saw that horrible, horrible report of the apartment building fire in New York City over the weekend. And I'm sure that there probably weren't good evacuation plans from and who was expecting there there to be a fire, but it can be disastrous. So fight or flee means know ahead of time what your parameters are going to be. How big is the fire? Is it too smoky to be able to breathe, to stay? Um, and in any case, before you make that decision, you should be calling 911.
SPEAKER_03Great information, Mary. Linda, let's talk a little bit about the PASS technique. I know that in Tennessee, with our Tennessee OSHA TOSHA program, even if you have a flee option, they still want the employees trained on the PASS technique. What does that mean?
SPEAKER_01Olivia, the PASS Technique is an acronym that serves as a reminder for how to operate a fire extinguisher. And as Mary said so beautifully, you know, your first option should be to escape if the route is clear. However, if the route is not clear and you need to pass through an area or maybe the only area to escape without using a fire extinguisher, or um, you certainly want to be able to use it in the office and be able to be trained on it. So think of the PASS acronym, PASS. The first thing you do to operate at fire extinguisher is pull the pin. And when you pull the pin, you make sure the nozzle is pointing away from you. So it's not going to be firing on you. You're not at the fire. You're not put the you do, then you follow A, aim. You aim that nozzle at the base of the fire. The first S stands for squeeze. Then you squeeze the lever slowly and evenly while you then sweep, which is the second S, you sweep the nozzle back and forth from side to side at the base of the fire. So that way you're trying to minimize or put out the fire at the point of origin so you can get by safely and evacuate. And I would recommend to our listeners, Olivia, if they've never held a fire extinguisher, pick one up and become familiar with it. Much like the AED device in your practice, when you have your CPR training every two years, you bring that device out at a minimum once every two years. We all know and would recommend here, as our divas would, that you should be laying hands on your AED and fire extinguisher, so to speak, more than you know, once every two years. But pick up that fire extinguisher and become familiar with it, because a medium to larger size fire extinguisher could weigh as much as 10 or 20 pounds. And if you're not expecting that and you're not capable of holding it, then that could be a challenge if you think you're going to use a fire extinguisher without any training or any familiarity to it. And then lastly, Olivia, in addition to the PASS acronym, the pull, aim, squeeze, and sweep technique, I would remind our listeners that a 10 to 20 pound fire extinguisher is going to discharge completely anywhere between 10 and 25 seconds. So it's not going to last a terribly long time. So being prepared in the event you would have to use one is very important. So thanks for asking about the past technique.
SPEAKER_03Thank you, Linda. Awesome information. And speaking of portable fire extinguishers, Leslie, can you mention some of the requirements in place for maintaining the extinguishers?
SPEAKER_00Why, certainly, Olivia. And you know, I find that the fire extinguisher is oftentimes forgotten about in a dental practice. Some dental practices have companies that maintain the fire extinguisher for them. It may be part of the building management responsibility. But OSHA says that employers must maintain the fire extinguisher, meaning that they inspect and maintain and test all portable fire extinguishers in the workplace and then visually inspect portable extinguishers or hoses at least monthly. And the annual maintenance check on portable fire extinguishers must be done. And this is where I find that sometimes we forget about that fire extinguisher. So they're required to record the annual maintenance date and maintain or retain this record for a period of one year after the last entry or own the life of the shell, whichever is less. And the shell, I believe that means by their the tank. And I found again that uh we sometimes overlook, even if we have a company that comes in during COVID, some of those uh companies that maintain fire extinguishers didn't make their rounds to everybody because maybe dental practices were closed or perhaps they weren't comfortable going out in public. Uh, but even pre-COVID, a lot of times as part of my inspection, I would look at the date on the fire extinguisher and see that one had not been inspected or recharged properly for a year or two or three past the expiration date.
SPEAKER_03Thank you, Leslie. I want to mention that with just with my clients here in Tennessee, we have had uh several dental offices that were completely destroyed with tornadoes. Matter of fact, one of the clients' offices was destroyed twice with different tornadoes in different seasons. One of my clients' offices that was destroyed, uh, luckily it was at night, not when anyone was working, but there were computers laying around the yard. And that brings up a different discussion on how do we protect patient information. And this doctor, this dentist, was very well versed in HIPAA, and that was his priority to collect up all of the computers in a safe manner and also any of the paper information that was laying in the yard. So the next episode for part two of this podcast, we will discuss the HIPAA considerations of emergencies such as tornadoes or other emergencies that might take place. Any other experiences that the other divas would like to share?
SPEAKER_02Just a reminder, I think I mentioned this earlier, but OSHA does expect those portable fire extinguishers to be mounted on the wall. Um, I have been in practices where they've been cited for having them sit underneath a sink or in a corner someplace. And then if you need it, it's you know you're scrambling to find it. So make sure that they are mounted. Also, make sure that you know the building code in your area and you can find this out from your local fire department. How many fire extinguishers do you need based on the size of your facility?
SPEAKER_03Good reminders. And I know for the information that Leslie was talking about, we find it helpful to keep task sheets just to make sure everyone is checking the portable fire extinguishers each month. Well, as the compliance divas, we bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please submit your questions to support at the compliancedevas.com. We will also list the reference that we've used from OSHA for their e tool on the references on our website. Thanks for tuning in. We'll see you again.