Time for a Recheck: Is Your Orthodontic Practice Adhering to Standard OSHA Safety Laws?

– Hello, my name is Alison Werner and I’m the Chief Editor of Orthodontic Products. Thank you for joining us for today’s episode of “In the Sterilization Room With Jackie”, where we talk to Infection Prevention Expert, Jackie Dorst about what you need to know about, to keep the orthodontic team and patients safe during the COVID-19 pandemic and beyond, and hopefully we’re coming up on beyond. For over 30 years, Jackie has been a consultant specializing in instrument sterilization, and infection control and prevention in the dental setting. She has degrees in microbiology and dental hygiene and has been a featured speaker at the American Dental Association and the American Association of Orthodontists. Jackie, it’s great to be back with you.

– Thank you, Alison. Uh, it’s good to be back on Orthodontic Products video and podcast now.

– Yes, exactly. This is part of our new podcast, um, program. So you can find us now on the Medqor podcast channel, but we’ll still be on YouTube and on our website, and so you can listen to us as either video or audio. So Jackie, today, we wanted to take a little bit of a, move away from the pandemic for a little bit. Like we said, hopefully we’re moving a little bit beyond and kind of return to the nuts and bolts of, you know, the sterilization room. So during the pandemic, we’ve been so focused on respiratory protection and those N-95 respirators and disinfectants and checking patients for symptoms, that maybe practices have let their attention lapse when it comes to other standard OSHA safety laws for the orthodontic practice. So, what are we talking about here when we talk about those standard OSHA safety laws?

– Well, you know, Alison, I, I proposed the topic to you today because I did a training session for a relatively new orthodontic practice last week. They’ve, they’ve opened their doors a year ago, and, of course they’ve been busy getting all the systems in place and even working with a consultant on, uh, you know, training the treatment coordinator and their marketing programs and, and as the practice grew, they’re hiring more employees, and the doctor contacted me and he said, “I know I need to get these OSHA systems into place. Can you help me?” And of course I said, “Yes.” So we agreed to print out their custom OSHA manuals for them and then have a two-hour training session for his three employees that he has. So, you know, it’s, it’s a relatively new practice.

– Mm-hm, yeah, yeah.

– And as I was putting it together, I thought, “Well, it would be good if we had photos from his office of the basic OSHA safety things.” And that’s where a couple of things came up, that I go, “Ooh, he didn’t know about this.” And it was basic. OSHA inspectors, when they come in, they’re industrial hygienists. So they’re gonna look at overall safety, that under the OSHA law, comes under the general duty clause and emergency preparedness. So while those were the things I, I sent him a list and said, “Would you take a couple of photos? And I’ll put these into the PowerPoint.”

– Okay, so let’s break this down. What are the four components we’re gonna talk about today?

– Well, fire extinguishers, number one.

– Okay.

– Any OSHA inspector that comes in is gonna look, “Do you have a fire extinguisher?”

– Mm, okay.

– And then number two is gonna be “Do you have a first aid kit?” And number three is gonna be, if you have chemicals, “Do you have an eyewash station around?” So I, as again, those, if an OSHA inspector’s there or if they’re reviewing safety, inspectors are gonna look at those common safety measures and “Do you have all of the record keeping and an OSHA manual and training for employees?” So, that was the photos I requested,

– Right.

– as I was putting everything together for this ortho practice.

– Okay, and then I know in us talking , I know that there’s actually a fourth component, but it’s only for certain states. Can you talk about that aspect?

– That’s right, we’ll talk about AED machines. Well, and we can go ahead and, and review that now. The AED, or defibrillator, doesn’t really come under OSHA requirements, but it’s sort of in that same safety category of fire extinguishers, eye wash stations, and first aid kits, and some states do require it. I happen to be located in Florida, and Florida, the Dental Practice Act requires that all dental offices have an AED, so it will vary from state to state. Usually it’s enforced by the Dental Board,

– Okay.

– But it may come under one of the other health agencies. So I think offices, if they want to know whether they need to have that AED machine, can contact either their Dental Board or their state dental association, orthodontic association. They should let them know that. But let’s, let’s go back to the very first element of this.

– Yeah. So that fire exting, extinguisher. What are the requirements there? What, where should this be located, et cetera?

– Well, OSHA says that you should have a fire extinguisher, and in the office, and it should be easily accessible. The employees should have training on it and know how to operate it. And one of the things that I noticed once the office sent me the photos, I enlarged the image, and I was able to see on these little yellow tags. It may be yellow or, or green, that it has an inspection date. Fire extinguishers, you know, they can lose the compression, compressed air in them, or maybe the chemical is no longer active. So fire extinguishers really should be inspected by the company that provides them on an annual basis. And I noticed that it had been over a year when I looked closely at that tag. So that, since it hadn’t been inspected, and the doctor, since all this information was relatively new to them, he said, “Well do we get the fire department to come in and inspect it?”

– And I said, “No, no, no, no, no. Look up the name on the tag of the company that provided it to you. And then you schedule them to come to your office and inspect it. Now, I have had, in some states, the office would pick up their fire extinguishers, and they would take them over to the fire department. And the fire department for a 10 or 15 dollar fee will inspect them.

– Oh, okay.

– And, and go ahead and, and stamp that tag, and you know, you’ve had your annual inspection on it.

– Okay, okay.

– And then the other part is everybody in the office should know how to use the fire extinguisher.

– Ah, yes.

– And know where it’s located.

– Right.

– So, we went through the training on, ” This is the lever that you use to release it from the mount where it’s mounted on the wall. And all fire extinguishers should be mounted on the wall at a level that the shortest employee can access them.” You don’t want them

– Oh, good point.

– Too high or too low, yeah?

– Yeah, yeah.

– You need a sign over it, that says, “Hey, this is where the fire extinguisher’s located.” And then, all fire extinguishers have a safety device that I lightly call a hand grenade pin. It looks like a little metal ring or a pin, and it’s the safety. And once you pull that pin out then it releases the fire extinguisher to activate it. So the, the nozzle or the, the tube or the hose, whatever you call it, you need to point that at the base of the fire away from you. And once you’ve pulled out that security or safety pin, now you can squeeze the trigger, and it will release the propellant to come out and put out the fire. So, the risk of fire in an orthodontic practice is really small, but we need to know where that fire extinguisher is and how to use it. Usually it’s gonna be the coffee pot, or perhaps, even in a patient’s car in the parking lot that we might need to reuse the fire extinguisher for.

– Okay. Okay. Okay, great. So, moving on, let’s talk about those first aid kits. What are the requirements there? Anything that practices should really be focused on?

– Yeah. All employers must provide an, a first aid kit for the employees. So don’t get confused. This is not that big black medical emergency box in it that has epinephrine and all of the other pharmaceuticals and safety that you would need if a patient had went into anaphylactic shock. But this is just a basic first aid kit that has band aids and antiseptic cream. And just like you would possibly have at home or maybe even keep one in your car. And, but just like the fire extinguisher it should be inspected on a regular basis to make certain that supplies have been replenished in there. Um, I would recommend inspecting it maybe on a monthly basis, depending on how frequently the items are used. And, you know, the employees need to know where it’s located. So a sign, if it’s stored in a drawer or in a cabinet, we need to put, “Hey, a, a green, it’s usually a green and white sign that says first aid kits stored here.” on the outside of the cabinet or door. And then as like this new orthodontic office, as they’re hiring new employees, everybody could readily see where that first aid kid is. And that’s also a good location to store that AED machine. Also, if they have one, either have it mounted on the wall where everybody can readily see where it is, or if it’s in a cabinet or a drawer, they need to have the sign on the outside of it, uh, identifying it.

– Oh, okay. Great. Okay. Now the eyewash station. What, what does this involve? Cause I know we’ve talked a little bit and it’s kind of there’s a lot to know here.

– It, it’s more complex than you would think. Everybody is familiar. Yeah. They familiar, you know, the frequently orthodontic practices have had that eye wash station that’s attached to a faucet in the sterilization room or in the laboratory and everybody knows it’s there and it’s got these little red or green plastic caps that go over it. And, you look at it so frequently that you don’t even see it anymore.

– Right.

– Well, really, eye wash stations are really important. If you get chemicals splashed into your eyes, such as the cold sterilization solution can be extremely toxic and damaging to eyes. And maybe somebody drops items into that cold sterile and doesn’t have their safety glasses on at the time and so the solution splashes up into their eyes. And one of the, the more hazardous chemicals that we use in an orthodontic office is etch. Etch is 35% to 37% phosphoric acid. And, you know sometimes ortho offices have even bought large dispensers of that and refilled syringes with it as an economy measure. And those syringes can get clogged. And say, you’re setting up for a bonding procedure and laying everything out and the assistant test the syringe, and maybe it’s got a clump or a lump in there and uses a little more foot, force to push that etch out. And if he or she doesn’t have on their safety glasses that could be another potential chemical injury.

– Yeah.

– Well, the eyewash station for rinsing the eyes out should be capable of delivering tepid water, not too cold not too hot for 15 minutes, at a gentle water pressure to rinse out the employee’s eyes. So, you don’t want have an, our station on the faucet that maybe has a single lever faucet, that could accidentally be pushed to the hot side.

– Oh yeah.

– And it would deliver hot water. Or like in the, the wintertime, if you’re in a really cold area um, that water coming outta the faucet can be icy cold. So, there is actually an, an, an ANSI standard, the American National Standards Institute standard for eye wash stations, that is referred to as the Z358.1. And in that standard, it states that the eyewash station should be a single action. That means that you just have one lever that you either push or pull to activate it, and that it will deliver water in the temperature range of 60 to 100 degrees Fahrenheit for that 15 minutes. And that it’s a gentle flow that will deliver 0.4 gallons per minute, not greater than 30 PSI or pounds per square inch. So pretty specific range with it.

– Yeah.

– Now, yeah. Most offices have not installed a, a separate eyewash station, which would have to have separate plumbing going to it. I know there’s one state, South Carolina, that has a state OSHA compliance system. And in South Carolina that is required. That you have a separately plumbed eye wash station that meets this ANSI 358 standard, C358.

– So, you really need to know what your state also requires.

– Exactly because, you know, we have 26 states in the United States that have their own OSHA state compliance system. Such as you’re in California. So you have call OSHA there. In Tennessee, they have TOSHA. So there are a number of the states, in Washington state they have WISHA. That does their OSHA state compliance with it. So it can vary a little bit from state to state, but then the other 24 states have used the federal standard. As with the, with it. So I think we’ll see, as they’re in the future, as maybe OSHA inspectors are coming in and doing more inspections, that they may look more closely at this ANSI standard and require that for offices that do have hazardous chemicals, that they might need to use an eye wash station for. So over the, during the pandemic, we’ve been, as you said so focused on those N-95 respirators and fit testing and testing for COVID. Are you positive? Are you negative? That some of these routine safety measures have been overlooked. So I’d encourage orthodontic offices to revisit them. OSHA does have in place for the next couple of years what is referred to as their national emphasis program. Um, OSHA is hiring more inspectors nationwide as the pandemics subsides. And they’re getting out to do more in office inspections. And at the top of the priority on that national emphasis program is workplaces where employees can be exposed to COVID 19 and with the new, with the in respiratory protection standard. But don’t forget the basics of safety. That first aid kit, fire extinguisher, and eye wash station and make certain that they’re working. And I, I would encourage you, to offices to put on their testing schedule that they test their eye wash station at least once a month to make sure that water’s still flowing from it. I know when I attended another safety conference with OSAP it was recommended by the speaker there that eyewash stations should really be tested at least once a week to validate that they were working and to flush any stagnant water out of them to make certain that healthy water was going through them. So, little bit complex but easy to manage when you have all the right information.

– Exactly. Well, thank you, Jackie, for breaking this down for all of our viewers and check back soon for the next episode of “In the sterilization room with Jackie” In the meantime, to catch up on past episodes or to check out the latest orthodontic industry news visit our website- orthodonticproductsonline.com Until next time, take care and stay safe.