#209 Where Would YOU be without PPE?

Personal protective equipment, otherwise known as PPE, is a critical element of workplace safety in dentistry.   In this episode, the Divas discuss OSHA's PPE requirements and some common errors that dental teams make with regard to PPE.

Resources:

• OSHA Bloodborne Pathogens Standard  https://bit.ly/3S8a5yJ
• OSHA Hazard Communication Standard  https://www.govinfo.gov/content/pkg/FR-2024-05-20/pdf/2024-08568.pdf
• OSHA Personal Protective Equipment Standards   https://www.osha.gov/personal-protective-equipment/standards

                                                 https://www.thecompliancedivas.com

Transcript

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SPEAKER_02 0:04

Welcome. I'm Leslie Cannon. I'm Mary Gavoni.

SPEAKER_03 0:09

I'm Linda Harvey. I'm Olivia Juan, and together we are the Compliance Divas. Welcome to the Compliance Divas podcast. My name is Olivia Juan, and I'll be your moderator for this episode. Today's discussion is entitled, Where will you be without PPE? We all know that PPE, personal protective equipment, is required in a dental setting. But as the compliance divas, we often find that this is a very common violation as we practice in dental settings day to day. So we hope that this episode would unveil some of the most frequent PPE violations. As the compliance divas, we bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please subscribe to the Compliance Divas podcast through your favorite podcast channel, or you can access the website, thecompliancedivas.com. Any resources that we mention will be available on the site. Please submit your questions to support at thecompliancedivas.com. Also, we would appreciate if you'd give us a review. So to promote long careers in dentistry, it's so important to follow the recommended personal protective equipment requirements and to understand how to select PPE properly based on the anticipated hazard. And as I mentioned, all of the Divas have so much experience in dealing with PPE violations as we continue to serve dental practices. But I would love to start with our long-term consultant, Mary, and have her talk to us about protective clothing because there seems to be a lot of confusion among dental team members on what is appropriate to wear in a clinical setting. So, Mary, how can you enlighten our listeners?

SPEAKER_02 2:28

Thank you, Olivia. I think that uh PPE violations in terms of protective clothing are probably the most common ones. So I want to start out by just reading the definition of personal protective equipment from the bloodborne pathogen standard, because that's the basis for what we talk about for what is appropriate. So, according to OSHA, personal protective equipment is specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes, for example, uniforms, pants, shirts, or blouses not intended to function as protection against a hazard, are not considered to be personal protective equipment. So, what this means is that if you are wearing scrubs, which would be a uniform of sorts, in a practice, it is not appropriate to just simply slip on a long-sleeve t-shirt underneath those scrubs to say, yep, my arms are covered and call it good. You must have some protective gown or jacket over the top of that. And think about the practicality of that. If you are wearing those scrubs with a long-sleeve t-shirt around the office all day long, you are getting exposed to and will have on your clothing spatter or splatter from hand pieces and so forth. And so now we wear that into the lunchroom and we sit with that contaminated clothing, or we go work at the front desk with that contaminated clothing. Now, granted, we're not going to be spreading HIV or some serious illness from that clothing, but certainly colds or flu or something else that may be on that clothing. Besides that, that clothing, again, has not been designed to be PPE. So you need something over the top so that when you do go into the break room, you can leave your jacket or your lab coat in the treatment area and not have to worry about being contaminated when you're eating or drinking and so forth. The bloodborne pathogen standard does say that that garment must be fluid resistant. It doesn't have to be waterproof, but at least it needs to prevent splatter or splash from soaking through onto your clothing or the skin underneath that garment. Now, lots of people favor short jackets and it isn't ideal, but think about when you're sitting down and there is aerosol being created, if your jacket doesn't cover your scrub pants, then your scrub pants are potentially contaminated. So I would say, and I'm sure my colleagues here will agree, that a knee length coat is best. And something that has a cuff with elastic or a knit cuff that you can pull the end of your glove up over your sleeve so that that's one of the most contaminated areas. You can buy disposable gowns if you choose to wear them. You can buy reusable gowns, which by definition from OSHA, you can wear until they are visibly soiled with blood. So that's a decision you have to make in your practice about how long you're going to wear the same gown. Most people change it every day. And you cannot take that contaminated laundry, the jacket or the lab coat or the gown. You cannot take it home to launder it. So it either needs to be laundered on site, you have a washer-dryer on site, or you use some kind of a commercial laundry service to take care of that clothing. But think about again what kind of contamination you have on those scrubs if you're not covering up your scrubs when you're at work all day. Or we see a lot of doctors who are wearing a dress shirt and a tie when they're working at chairside. And that becomes contaminated the minute that you pick up a handpiece or an airwater syringe or an ultrasonic scalar.

SPEAKER_03 6:46

Wow, Mary, you hit on so many aspects relating to protective clothing. So I appreciate you mentioning long-sleeve t-shirts as an issue because during the cooler months, we see people wearing t-shirts under the scrub top, and it is not recommended. Have to be able to peel that outer layer off without cross-contaminating. And also, I appreciate that you mentioned about they cannot take the cloth jackets home to launder. It's the employer's responsibility. And disposable jackets are or gowns are a great option. I wanted to supplement your thoughts with an experience with a pregnant worker. The cloth jack didn't fit her any longer. It's like she couldn't close the jacket. And, you know, if it's a temporary thing, such as a pregnancy, either order the correct cloth jacket that fits or put the individual into the disposable gown so that they have adequate coverage during that term. So proper fit is important. And I love that you mentioned the three-quarter length jacket. I've been a proponent of that for years. And I was so proud when I was on site a week ago at a client's office that I've served for 25 years. I was so proud to see that they had all three-quarter length jackets. It just looked professional and it was promoting safety for those individuals. So great points. I'd like to change gears a little bit and pick Linda's brain, another well-seasoned consultant, about eye safety. What can you share with us, Linda, based on your experience?

SPEAKER_00 8:26

Olivia, like Mary and all of our divas here today, we have experienced issues with team members either not being aware of the need for better eye protection, or perhaps they perceive it as a low risk. You know, something's not going to fly into my eye, I'm going to be fine, you know, I'm wearing my safety glasses or I'm wearing my prescription glasses, whatever the case might be. But I'd like to help our listeners understand exactly, though, what the standards talk about. And when you think about OSHA's bloodborne pathogen standard and the requirement there, OSHA relies on an organization named ANSI, the American National Standards Institute, to do the testing and the research and set the behind-the-scenes standards, if you will, that OSHA uses when they're investigating or auditing any practices. So when we think about ANSI, I want to take this back to a couple of years ago when their national eye safety standard was updated. And the backstory on that is due to there were some injuries that were occurred with a dentist up at Tufts University, who before he became a dentist was an engineer. So he and another engineer friend began to tackle the eyewear problem in the sense of this, what they've been calling the bottom gap phenomenon. You see, what they found out was that there's a gap underneath your glasses. And I don't care how large or small your prescription glasses are, for example, but there's still a space under that lower edge of your glasses and between your cheek and that space. And that's where debris, blood, saliva, aerosols, and any other kind of hazardous materials can shoot through that little space. And all it takes is a little sliver because our eye is not very big and it doesn't take much debris or any flying objects to create an injury. So this new eyewear standard requires that we have goggles or face shields. We can no longer wear our prescription glasses with side shields on them. Yes, we do want glasses, or I should say goggles, with side shields, but the goggles also have that under-eye protection with a little kind of a curved ledge and the same thing over the eye. So this is a great opportunity to evaluate the eyewear that you're currently wearing in your practice and see how you can be safer. Olivia, personally, I love it when dental assistants who don't happen to wear loops wear a face shield. And I encourage all the dental assistants to do this for even just a couple of days and see how much spray and splatter is on that face shield that's going all over their face and their personal glasses if they're just wearing prescription glasses. Of course, you still have to wear your mask if and/or if you're wearing eyeglasses or prescription glasses, you'd still wear those underneath your face shield as well. But many of our listeners, Olivia, dentist and hygienist in particular, are all wearing loops. So I encourage you to go back to your manufacturer of your loops and determine whether your loops have any add-on features or inserts that can help close that bottom eye gap. So please evaluate your loops. And if you're in the market for new loops or you never had loops and you're investigating them, I would certainly make eye protection one of your top priorities with when selecting a new brand of loops. But Olivia, one thing I want to point out in particular is that OSHA has injury reporting requirement. If there's a loss of an eye that's due to a work-related injury, that's reportable to OSHA within 24 hours. And this is a scenario that I always draw. And that is you get something in your eye, you go immediately to the doctor, they send you to the ophthalmologist because you have to handle this as a workers' work-related injury. You don't get to go to your personal physician, you follow the workers' comp laws in your state as well, and you get referred to the ophthalmologist. Well, suppose it takes several months of following them with whatever issue happened to your eye, whether it's a chemical splash or an object that was embedded that flew into your eye, a little scrap of amalgam. And let's further suppose, Olivia, as an attorney, you can appreciate this that a few months later, that injured worker loses their eye. It doesn't matter that the injury happened more than 24 hours after dates ago that occurred months ago, is still reportable to OSHA because now you're losing your eye or you're losing sight in your eye. And that's reportable to OSHA within 24 hours. So I just like our team members, all our team members to be as safe as possible, Olivia, and wear the proper eye protection, either goggles or a face shield.

SPEAKER_03 13:02

Thank you, Linda, for all that information. And I agree, when you wear a face shield, it's a sobering reminder of how much splash and splatter, aerosol, drips, whatever is hitting that shield. And it concerns me when I'm on site how many people are either not wearing safety glasses or a shield, or they're wearing regular prescription glasses, which are not the same thing. So thank you for sharing all your knowledge on eye safety. Leslie's going to talk to us about gloves. And once again, she has so many years of experience and even having served as a chair side assistant. Leslie, what can you share with us that's potentially violating the law as it relates to gloves?

SPEAKER_01 13:55

Well, Olivia, when I first started working in dentistry, we were not wearing gloves at all. So I put that point of reference out many times when I talk about how we had trouble learning how to wear gloves. But then once we learned how to wear gloves, we would never work on a patient without actually having gloves on. We would never go back to barehanded. And today, there are many times where we misuse gloves. And I think people are just so busy with thinking about what's on the schedule or what emergencies have to be seen or what the procedure is that they become forgetful. And so changing gloves is important, making sure that we don't cross-contaminate the sequence of donning gloves and donning PPE. We shouldn't be contaminating our gloves when we are donning our PPE. Washing hands and donning gloves should be the last thing that happens before hands go to either patient care items or to the patient's mouth. We should be mindful of what we are doing when we're going to get a needed item, in that if we have to open a drawer that we're not contaminating the gloves or the drawer handle, uh the changing gloves, taking off gloves, washing hands, getting the needed item, washing hands or alcohol hand sanitizer, redonning gloves, and then coming back to patient care. There's multiple types of gloves that we have available to us. And we first started out, we only had latex gloves, and then we had sterile surgeons' gloves that were introduced. And when we perform procedures that are invasive, the standard of care and best practices would be to don sterile gloves and to do it aseptically, which is either an open cuff or a closed cuff method. Individuals should be very well-versed and do some practice on how to don sterile surgeons' gloves again so that they are donning them aseptically and not creating a point of contamination that might become harmful to the patient when they're performing an invasive dental procedure. In the sterilization room, utility gloves are the best bet. And again, that is a point of contention I know for a lot of team members that feel that they're bulky and it's difficult to handle contaminated items. I remind them once again that when we first started wearing exam gloves to provide patient care, we felt they were bulky and that it was hard to pick up an item. We had to learn how to pick up a burr and learn how to use, let's say, a cotton pliers to get that burr or magnetic burr block. But we became very, very used to them and again would never go back to working barehanded again. Once you become familiar with using utility gloves, it becomes routine. And and if you've ever seen someone get poked with an instrument in the sterilization room, you'll you'll never want to perform instrument processing without wearing utility gloves. It is such an avoidable type of accident. And I'm not saying that utility gloves will prevent a sharp contaminated instrument from slicing through it. They're not puncture-proof, but they're puncture resistant. And I can imagine that if there was a contaminated instrument, if it did penetrate the glove, what would likely happen would most of the debris would be on the outside of that utility glove, hopefully not make much of its way into the bloodstream of the person who is wearing the gloves. So you have a little bit of a buffer between you and those potentially infectious materials when you wear utility gloves. So I encourage everyone to think about the gloves that they're using. If you find that you are wearing gloves that are too tight, think about upping to the next size because tight gloves can be problematic for individuals and cause ergonomic injuries. If you are wearing gloves that are cheap and they seem to rip and there's holes and penetrations that occur frequently, think about upping to a different brand of glove. Some people have longer arms than others. And when they wear the exam gloves, there's a gap between the exam glove and the cuff of their clinical jacket, which exposes their forearms to whatever aerosols and spatters. So there are different gloves that have a little bit longer type of reach between the glove, wrist, and actually where the cuff of the clinical jacket is. So when it comes to gloves, there's lots of choices. There's different materials, there's different sizes, there's different uses for gloves. And with the employer responsible for selecting the proper PPE for the task, there should be a concern for OSHA compliance when it comes to selecting gloves.

SPEAKER_03 18:56

Thank you, Leslie, for your insight. And I appreciate the fact that you mentioned utility gloves. When I'm on site auditing and making an assessment, they know they're supposed to wear them and then they express dissatisfaction with how they fit. So I think they should try to get a better sizing or consider the disposable utility gloves. That might be a good option. But you have to wear them. And also I like that you mentioned the sterile surgeon's gloves. If I ask, well, do you do surgical procedures? Like, like what do you mean? Well, do you do implants? Do you do surgery? Do you do surgical extraction? Where are the sterile surgeons' gloves? And so that, as you mentioned, is part of the guidance. So thank you for giving us so much good information about gloves as part of our personal protective equipment. I wanted to mention that there was an OSHA violation a couple years ago where the dental assistant was not wearing a mask or protective eyewear during operatory cleanup. So, in other words, she was using the wipes and she had gloves on and a jacket, but not eye safety or mask. And her theory was: well, these are just wipes. But the OSHA inspector simply looked at the canister of wipes in the PPE section, and the manufacturer advised full PPE. And so I mentioned that quite a bit in training groups that we have to look at when we're working with chemicals, what is recommended by the manufacturer. And those are certainly violations that we can avoid easily. So during your training sessions, you know, if you're using wipes or whatever product line, pull out the product and read the label together so that we can all be on the same page with personal protective equipment. What are your thoughts, Mary?

SPEAKER_02 20:56

I just wanted to add on to what Leslie said about all the choices of gloves. I hear from team members frequently that they've gone up a glove size because they were feeling some tension like on their thumb when they're wearing gloves. And if you're prone to or having symptoms of carpal tunnel syndrome, then something you may want to consider is right-left gloves instead of ambidextrous gloves because it makes a big difference in the fit and how those gloves are formed. The gloves that are ambidextrous are formed on a mandrel or a model where the hand is completely flat and not flexed at all. And the part of the hand that flexes the most when you're wearing the gloves is the thumb area. So you don't want a glove that's too large to get rid of the tension altogether because then it's not going to fit you as well. But rights and lefts, and it used to be a huge cost difference between the two. It's not as bad as it used to be. And one of the big advantages for our doctors who are doing surgical procedures, the sterile surgeons' gloves do come hand specific. So they're going to be more comfortable for longer procedures.

SPEAKER_03 22:10

Thanks for adding that point, Mary. I totally forgot about the ergonomics aspect of gloves. So those are some good valid points to share with our listeners. So we appreciate everyone making time to tune in to the compliance divas podcast, particularly this episode, Where Will You Be Without PPE? 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 thecompliancedeivas.com, and any of the resources that we mentioned will be available for your review. Thanks again and see you next time.