Congratulations!  You are on your way to OSHA compliance! While this book is not an "OSHA" manual, SOPs are an integral part of regulatory compliance. And, if used appropriately, SOPs make adhering to state and federal regulations easier than you think.

 

OSHA is concerned with the safety of your employees and the hazards present in their workplace. Although not inclusive of all potential dangers, your clinical procedures and other related tasks comprise the majority of the occupational hazards in your office. If all of these job tasks are "SOPified,� you've already done half the work involved in regulatory compliance!

 

The Back Office and Hygiene sections of this book represent the "front lines" of OSHA compliance in a dental office. The SOPs in these two sections will be the ones most affected by regulatory and safety concerns, an important fact to keep in mind as you edit and customize them to suit your practice particulars. In that vein, you will notice that some of the sample SOPs that follow have "safety-" or "regulatory-driven" steps, but understand they are only examples and may or may not apply to your office!

 

Because of the near-infinite variables in modern dental offices (and the differences in some state plans), it's impossible to provide you ready-made, OSHA-compliant SOPs for your unique practice. But, armed with this book and these sample SOPs, you are well on your way to achieving this goal.

 

Manuals and Plans

 

Retail OSHA Manuals are common in dental offices and widely available from diverse sources. These �ready-made� binders often provide information about regulations and blank forms and plans, making "compliance" seem to be just a matter of filling in a few blanks and filing MSDSs. While these tools are extremely useful, the common misconception is that they are stand-alone volumes. However, none of them describe how procedures are performed in your office, which chemicals you use, or the specifics of your equipment�all of which affect the scope and details of your compliance programs. A "SOPified" office will have all that information documented in an easily understood, readily revisable, and workable form.

 

In addition, these manuals are usually inclusive, meaning the programs and plans are all in one place. While this provides for ease in filing, it can work against you during an inspection. If an inspector asks you for your Bloodborne Pathogens Exposure Control Plan, please do not hand him or her your entire "OSHA" binder! Having your programs organized separately so each is readily presentable and independent of the others will facilitate a cooperative and efficient inspection process, and enable your employees to access the same information quickly and easily. Just as I recommend with your SOPs manual, make these programs easy to find and easy to use.

 

These Plans don't have to be lengthy, but they must be accurate and complete. The following Plans are the most common, but your office may require others:

 

�       Hazard Communication Plan: Contains a master list of all the hazardous chemicals present in your office and where they're stored, provisions for container labeling, collection and availability of Material Safety Data Sheets (MSDSs), and an employee training program. Your individual MSDSs should be filed elsewhere, in a designated file or dedicated binder that is "readily accessible" to your employees.

 

�       Bloodborne Pathogens Exposure Control Plan: Documents all the procedures and related tasks where occupational exposure to blood and Other Potentially Infectious Material (OPIM) occurs, necessary training for employees performing these procedures, required protective equipment, engineering and administrative controls, vaccinations, and post-exposure procedures.

 

�       Personal Protective Equipment: Certifies your performance of a hazard assessment for all job tasks and the PPE required for each, covers the training provided for PPE such as wearing, caring for, limitations and disposal.

 

�       Fire and Emergency Plans: Includes plans and procedures (such as exit routes, personnel responsibilities, etc.) during a fire or other emergency (tornado, earthquake, etc.).

 

�       General Office Safety and Housekeeping: Covers storage, floors, some waste, trips and slips and other preventative measures to reduce accidents.

 

�       Waste Management: Details the handling and disposal of hazardous and biohazardous wastes, also reflects state and local requirements.

 

OSHA, the Back Office, and SOPs

 

As you can see, SOPs can make it very easy to identify where your hazards are. When you begin writing your SOPs, you will start by documenting what you�re actually doing. The next step will be to use this information to identify the hazards present in these tasks. To do this you must first understand what OSHA considers a hazard: bloodborne pathogens, hazardous materials, noise, heat, sharps...the list goes on. Each of these is addressed in the regulations, and depending on the circumstance, might need to be addressed in your Plans and SOPs. Just because a chemical is hazardous and your employees use it, it may or may not warrant special precautions. It's the probability and frequency and extent of employee exposure that determine the necessary precautions. That's why your hazard assessment is so important. Based on established guidelines (see publications on page 3), the employer is granted some leeway in the development of workplace policy and programs.

 

After a thorough hazard assessment and careful review of your compliance Plans, you will see where to refine and edit your SOPs to include the �safety-� or �regulatory-driven� steps necessary to ensure complete agreement between the Plans and your SOPs.

 

Don�t stop here! After you have edited your procedural SOPs to agree with your compliance plans, review the OSHA and Regulatory Compliance Coordinator performance agreement in the Job Descriptions Section of this book. There you will find a list of additional tasks that, although are not directly related to patient care, must occur in a dental office. SOPs should be written for these tasks as well, with primary, shared, and backup assignments noted.

 

 

 

 

Without standard operating procedures, it is very easy to fall into saying one thing and doing another, as your staff may be aware of the OSHA regulations, but not taught how to incorporate them into routine procedures. Having compliance-minded SOPs in place indicates that you're committed to training your employees correctly, not just paying lip-service to the safety rules by filling in a few blanks in a generic binder. This level of commitment could demonstrate "good faith" to an inspector�that you are implementing the required plans, training and documenting to the intent (if not the letter) of the law. Penalties may be reduced up to 25% in recognition of this �good faith� commitment�provided other criteria are met.

 

OSHA knows the regulations are hard to navigate and often difficult to interpret, so they provide numerous resources in the form of handbooks and guidance documents. Some of the actual standards also have guidance sections written in, and while these sections of the regulations are not enforceable, they can provide excellent insight into how to comply. The following publications are available free from OSHA, available on their website.

                                                                                   

�       Controlling Occupational Exposure to Bloodborne Pathogens in Dentistry (PUB. #3129)

�       Assessing the Need for Personal Protective Equipment: A Guide for Small Business Employers (PUB #3151)

�       Chemical Hazard Communication (PUB. #3084)

�       Hazard Communication Guidelines for Compliance (PUB. #3111)

�       Job Hazard Analysis (PUB. #3071)

�       How to Prepare for Workplace Emergencies (PUB. #3088)

�       How to Prevent Needle Stick Injuries (PUB. #3161)

�       Training Requirements in OSHA Standards and Training Guidelines (PUB. #2254)

 

The Centers for Disease Control and the National Institute of Occupational Safety are also excellent resources. While not enforceable law, these organizations conduct research and affect OSHA's mandates. I suggest the Recommended Infection-Control Practices for Dentistry, MMWR 42(RR-8), available from the CDC.

 

What�s the bottom line? Documentation! Keep your plans short, accurate, and workable. Reference them in your SOPs. Make sure your SOPs agree with and reinforce your plans. Then train your staff on both, showing them how the office compliance programs and SOPs work together to ensure their ongoing safety while providing exceptional care. After SOPs implementation, regulatory compliance can be downright easy! Your staff will already be primed to doing things by the book, the right way every time.