福利姬视频

Employers have responsibilities for the occupational safety of their employees.  The Occupational Safety and Health Administration () is the U.S. governmental agency within the Department of Labor that has the mission to assure the safety and health of America's workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health.  OSHA accomplishes this task by creating standards that address potential workplace hazards.  The Agency was established as part of the 1970 Occupational Safety and Health (OSH) Act.¹  For dentistry, infectious disease and hazardous chemicals are examples of potential workplace hazards of concern; the following sections will address certain OSHA standards specific to dental offices. When there is no standard, the Agency may use OSHA’s “General Duty Clause” to guide regulatory enforcement for occupational exposures.

Training of employees occurs when the employee begins the job, and at least yearly thereafter.  Employers should provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure. The additional training may be limited to addressing the new exposures created.²  Engaging with the OSHA online resources (see Additional Resources section below) can improve knowledge of OSHA requirements and familiarity with standards facilitates compliance.

Regulatory Issues

OSHA’s requirements are federal regulations and are found in Title 29 of the Code of Federal Regulations ().  Thus, they are enforced by law, as opposed to guidelines and recommendations set forth by agencies and organizations like the Centers for Disease Control and Prevention (CDC) and the ADA.  OSHA standards related to dentistry are highlighted , and interpretations and directives of enforcement are available on .  The 福利姬视频has developed resources to provide members with insight about implementing the .

While federal regulations such as OSHA provide a base level of regulations for compliance, local and state regulating authorities and agencies may have additional or specific requirements that exceed federal OSHA standards.  For example, a state dental board may require compliance with .³ Furthermore, consideration of additional guidelines from other regulatory bodies, e.g., the CDC, may be prudent.

The following sections address many of the OSHA compliance issues that a dental practitioner might face, as well as other issues that may not be covered by OSHA, but that may be regulated by state or local laws or fall under other federal agency guidelines and recommendations.

The OSHA Bloodborne Pathogens Standard (29 )² is designed to protect workers exposed to blood or other potentially infectious materials (e.g., saliva in dental procedures), and covers training, hepatitis B virus vaccination, personal protective equipment, engineering and work practice controls, housekeeping, and regulated waste.  OSHA has a “” for the Bloodborne Pathogens Standard, as well as an updated page that covers .

Personal protective equipment (PPE, including gloves, gowns, masks, and eye protection) must be provided by the employer as well as cleaned and maintained to provide functional and protective efficacy, according to .⁴ It is the responsibility of the employer to assess risk from hazards and to make appropriate PPE available. Employees may use their own PPE, but the employer is responsible for its maintenance and cleaning. Further information from OSHA is available on their . Frequently asked questions regarding PPE use in dentistry are posted on OSHA鈥檚 website in a .⁵ The bloodborne pathogens standard also addresses PPE, at .²

As part of the Personal Protective Equipment (PPE) regulation, OSHA has established a subsection describing the PPE hazard assessment process for determining potential workplace hazards and implementing control measures.  According to , the employer must assess the hazards that may demand the use of certain categories of PPE, and further (1) make available the appropriate PPE for each hazard type, (2) communicate these PPE requirements to staff, and (3) ensure proper fit.  Finally, the employer must verify the hazard assessment in a written document, including information regarding the workplace assessed, the person verifying the assessment, and the date the hazard assessment occurred. Nonmandatory compliance guidelines on conducting the assessment and implementing requirements can be found in . For dentistry, examples of workplaces hazards include not only the risk of airborne and bloodborne pathogens, but also chemical, eye and noise hazards.

Requirements pertaining to respiratory protection PPE such as N95 masks are found in . In a workplace where respirators are necessary to protect the health of the employee, or whenever respirators are required by the employer, the employer must develop and implement a written respiratory protection program with required worksite-specific procedures and elements. More information about OSHA鈥檚 respiratory protection standards are available in the OSHA publications and .

General information about identifying and assessing hazards in the workplace is available in an OSHA resource entitled , which describes six steps in detail:

1. Collect existing information about workplace hazards
2. Inspect the workplace for safety hazards
3. Identify health hazards
4. Conduct incident investigations
5. Identify hazards associated with emergency and nonroutine situations
6. Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control

A component of OSHA compliance is a written exposure control plan, which applies to both bloodborne pathogens and hazardous chemicals (in ).⁶  The OSHA publication, , contains sample exposure control plans for both.⁷

Employers are responsible for offering the hepatitis B virus vaccination to employees within the first ten days of an employee beginning their position. Employers are also required to cover the cost of the vaccinations.² Employees may refuse vaccination, and OSHA provides a declination form for this purpose. An employee who has refused the vaccination may opt to receive it at a future date. No booster is currently recommended for persons with normal immune status who have been fully vaccinated.⁸ Although studies are ongoing to assess whether booster doses of HBV vaccine will be needed in the future,⁹ recently published data from a 30-year cohort follow-up suggests that booster doses may not needed.¹⁰

Needle safety may be approached through both work practice controls—such as prohibition of two-handed needle recapping, and engineering controls such as sharps containers, masks, gloves, and devices for one-handed needle capping. “If recapping must be performed, it must be accomplished by means of a recapping device which adequately protects the hands or a properly performed one hand scoop technique.”¹¹ Engineered needle safety products are also ways to help reduce and eliminate percutaneous exposure. Needleless systems, if available, are recommended.  Resources on “Safer Needle Devices” may be found on the Bloodborne Pathogens Standard page on .¹²

Requirements for sharps containers can be found in section 1910.1030(d)(2) of the .² Containers for contaminated sharps must be closable, puncture resistant, leakproof on the sides and bottom, appropriately marked or color-coded, and kept upright during use.² Mounting the container unit is a method of keeping it upright, but it is not mandatory.¹³

Please note that OSHA does not specify where sharps containers are to be located in a dental office.  OSHA has indicated that the employer is to determine placement based on location accessibility and reasonable proximity to the area where sharps are used. According to the answer to Question 39 in OSHA鈥檚 , 鈥淪harps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used (e.g., patient care areas) or can be reasonably anticipated to be found (e.g., laundries).鈥�¹⁴

In the event of an exposure incident (e.g., needlestick, sharps injury), employers are required to make available to the exposed employee a confidential medical evaluation and follow-up that includes: documentation of the exposure; identification of the source individual; testing of the source individual鈥檚 blood for infectivity status (i.e., HBV, HIV); collection of the blood and testing; post-exposure prophylaxis, if indicated; counseling; and a healthcare professional鈥檚 written opinion, among other requirements.  A complete list of requirements of the standard may be found in section 1910.1030(f)(3) of the .¹⁵ For more information, the 福利姬视频 and OSHA developed the 鈥�Employer Obligations After Exposure Incidents鈥� for dental professionals.¹⁶

According to 鈥溾�� regarding the OSHA Bloodborne Pathogens Standard, employers are responsible for laundering gowns and lab jackets.  Dental practices may install washing machines in the office, they may contract with commercial laundry services, and disposable gowns and jackets may also be used.  Scrubs, if worn under PPE, are generally not covered by the laundry requirements of the standard unless the scrubs do become contaminated with blood or other potentially infectious materials.  Employees are not permitted to take contaminated laundry home.¹⁷

OSHA requires disinfection of environmental surfaces with an 鈥渁ppropriate disinfectant.鈥�¹⁸ Appropriate disinfectants include a diluted bleach solution and Environmental Protection Agency (EPA) -registered antimicrobial products.¹⁹ Fresh solutions of diluted household bleach made up every 24 hours are also considered appropriate for disinfection of environmental surfaces and for decontamination of sites. Contact time for bleach is generally considered to be the time it takes the product to air dry.

OSHA does not require offices to replace carpet in dental operatories, nor does it address the type of flooring in the Bloodborne Pathogen Standard.²  In terms of the cleaning routine (29 CFR 1910.1030(d)(4)(i)), OSHA states the 鈥渆mployer must determine and implement an appropriate written schedule of cleaning and decontamination based upon the location within the facility.鈥�¹⁸ The Centers for Disease Control and Prevention (CDC) suggest 鈥渞eplacement with nonporous material when it is time to replace flooring.鈥�²⁰

There are no definitive OSHA regulations on nitrous oxide or anesthetic gases other than which regulates inspections, safety, and handling of compressed gases.²¹  Nitrous oxide is mentioned in the OSHA guideline, . The guideline is “advisory in nature, informational in content, and […] intended to assist employers in providing a safe and healthful workplace through effective prevention programs adapted to the needs of each place of employment.”²² Information from the National Institute for Occupational Safety and Health (NIOSH) on the safe use and control of nitrous oxide may be found .²³

Recommendations from the 福利姬视频for the safe use of nitrous oxide in the dental office may be found at http://www.ada.org/en/member-center/oral-health-topics/nitrous-oxide.

While addresses the first aid kit and first aid training required at all workplaces, it does not include specific guidance about a first aid or emergency kit for a dental or medical office, nor does it provide a list of required contents. Many states have adopted the ANSI Z308.1 specifications for minimal contents, and it is highly recommended that contents are suited to meet the expected needs of the dental practice. OSHA provides an appendix to 1910.151, , which states “Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.”²⁴ The 福利姬视频has published recommendations for ²⁵ as well as .²⁶ Updated information may be found on our Oral Health Topics page on Medical Emergencies in the Dental Office.

The OSHA Ionizing Radiation Standard () regulates occupational exposure and covers exposure and control.²⁷ This Standard is incorporated in the following recommendations.

The ADA/U.S. Department of Health and Human Services’ Dental Radiographic Examinations: Recommendations for Patient Selection and Limiting Radiation Exposure²⁸ contains a section on “Operator Protection” that addresses occupational safety, including the wearing of dosimeters by pregnant personnel, barrier shielding, and work practice controls such as standing behind the direction of the beam.  Recommendations for hand held x-ray units, including holding the device at mid-torso height, orienting the shielding ring properly with respect to the operator, and keeping the cone as close to the patient’s face as practical.

Additional information on radiation safety for dentistry may be found in , a publication of the National Council on Radiation Protection and Measurements.^{29, 30}

The 1994 version of the OSHA Hazard Communication Standard (), designed to protect employees from exposures to chemicals in the performance of their jobs, was modified to conform to the United Nations 鈥淕lobally Harmonized System of Classification and Labeling of Chemicals.鈥�³⁰ The new OSHA Hazard Communication Standard (effective date May 25, 2012)³¹ now includes a new 鈥淪afety Data Sheet鈥� (SDS; previously known as 鈥淢aterial Safety Data Sheet鈥� or MSDS) format organization, and the use of pictograms to identify chemical hazards.  Compliance with the new format was required beginning June 1, 2016.

Labeling and Pictograms

The 2012 OSHA Hazard Communication Standard³¹ requires manufacturers to label their products in accord with the new requirements, including pictograms of chemical hazards (e.g., corrosives, gases under pressure, flammables, explosives).  Employers are responsible for making sure that products they use are properly labeled.  For products that are transferred to smaller containers, employers are allowed to create their own labels, as long as they communicate the hazard information specific to the chemicals.^{32, 33} Examples of pictograms follow:

Acute Toxicity	Corrosives

Safety Data Sheets鈥擡lectronic Storage and Access

According to the 2014 OSHA publication, ,³² (pp. 20-21) employers must maintain copies of safety data sheets in their workplaces, and must ensure that safety data sheets are readily accessible. Compliance with the accessibility requirement may be accomplished in a variety of different ways, including in a binder or electronically.  If electronic, a back-up system must be in place to provide ready accessibility. 鈥淎ny approach may be used,鈥� if it provides the information when needed.³² A record of each hazardous chemical must be maintained for 30 years.^{6, 34} Record-keeping standards6 may be found in Section , and a description of alternative record-keeping in a .³⁵

Eye and face protection is covered under , and OSHA provides an e-tool to assist in selecting appropriate protection according to hazard. It is the responsibility of the employer to assess risk from hazards such as “liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation”³⁶ and to ensure that proper eye protection is utilized.

As noted in the previous section, safety data sheets that accompany products used in dental offices identify which products are corrosive and/or caustic. The OSHA standard for Medical and First Aid (), contains a requirement that employers provide “suitable facilities for quick drenching or flushing of the eyes and body” in situations where employees may be exposed to corrosive materials.³⁷

In a ,³⁸ OSHA has acknowledged that the Standard does not require employers to have an emergency eyewash if none of the materials used in the work area is an injurious corrosive chemical; however, the letter also states:

“…while not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI Z358.1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of ’hazardous material’ would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans.”

In the event of an inspection of a dental office where corrosive materials are in use, a workplace without an eyewash station (i.e., “suitable facilities”), could be cited by OSHA under 29 CFR 1910.151(c).  Information about eyewash stations is available from the Organization for Safety, Asepsis, and Prevention (OSAP).³⁹

For dental offices with , consult your area administrator for applicable requirements.

OSHA does not regulate sterilization of dental equipment, but state and local regulating authorities or dental boards may require compliance with CDC infection control standards. The 福利姬视频provides a number of resources in the Oral Health Topics pages for Infection Control and Dental Unit Waterlines, as well as in the 福利姬视频Center for Professional Success Managing the Regulatory Environment (login required).

Although the Bloodborne Pathogens Standard discussed above addresses exposure to medical waste, disposal of medical and hazardous waste is generally a state and local regulatory issue. More information may be found in the Medical Waste Disposal section of the 福利姬视频resource Managing the Regulatory Environment(login required)

The Occupational Safety and Health Act of 1970, Section 5, Duties,⁴⁰ states:

鈥�(a) Each employer 鈥� (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.鈥�

In the absence of specific standards, this General Duty clause covers occupational safety in dental offices, including ergonomics, nitrous oxide, and workplace violence, and other occupational safety and health exposures.

POLICIES AND RECOMMENDATIONS ON OCCUPATIONAL SAFETY AND HEALTH
(Trans.2016:322)

Resolved, that the 福利姬视频recognizes the importance of engineering and work practice controls recommended by the Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control and Prevention in preventing the transmission of bloodborne pathogens from needlestick and other sharps-related injuries in dental settings, and be it further

Resolved, that the 福利姬视频encourages dentists to maintain knowledge of and compliance with federal standards and other applicable regulations for eliminating or minimizing occupational exposure to bloodborne pathogens and preventing injury and illness in dental settings, and be it further

Resolved, that it is the position of the 福利姬视频 that its members, in an effort to promote a safe workplace, use materials in the dental health care setting that have been appropriately labeled by the manufacturer or distributor to comply with the OSHA Hazard Communication Standard, and for which the manufacturer/distributor has supplied a current safety data sheet (SDS), and be it further

Resolved, that the 福利姬视频support its members by providing access to current information, forms, and prototypes as needed to help them comply with occupational safety and health requirements affecting dental health care settings, and be it further

Resolved, that the 福利姬视频encourages and supports fair systems of compliance with applicable state and federal law(s) for preventing injury and illness in the dental office.

福利姬视频
Adopted 2016

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福利姬视频Store:

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福利姬视频Oral Health Topics:

• Infection Control and Sterilization
• Medical Emergencies in the Dental Office

Occupational Health & Safety Administration

• OSHA’s
• and

Centers for Disease Control and Prevention Division of Oral Health

• (2003)

National Institute of Occupational Safety and Health (NIOSH)