Most dental offices know about OSHA. Some are even aware that Minnesota has their own state plan. After that it tends to get foggy. Unfortunately if a dental office only half pays attention to OSHA they may not be compliant with them as well as several other agencies.
Besides Federal (OSHA, EPA, FDA and DOT) there are several Minnesota agencies we need to be familiar with and know the requirements. In order for Minnesota to have their own they need to be above and beyond the federal standard. So state will always supersede federal. It is up to us to know the differences and follow them. If ever an office is in doubt always follow the strictest standard and sometimes it is the manufacturer.
Bloodborne Pathogen Training upon employment (before employee is put in a position of a possible exposure) and at least annually
- Hazard Communication / Employee Right to Know Training upon employment and at least annually
- Safe Patient Handling training and review annually
- How contaminated laundry is handled
- Enforces the MDH protocol for TB
- Baseline upon hire
- Annual risk assessment
- Have a sign
- Flush for 3 minutes weekly
- Get to within 10 seconds
- ANSI approved
- Hands Free
- Temperature Controlled
Depending on pH of chemicals we pour/mix may need to be a one step and no corners/stairs to get to station
- Check monthly
- Service annually
Sharp Safety Device Evaluations annually
SDS on all active products
Secondary container – new labeling system
Minnesota OSHA primary concern is with employees’ safety and have a safe work environment. They are not specific to dentistry. Dentistry falls under OSHA’s General Industry Standard. Inspections are compliant driven. If they are in your office – they are there for a reason.
EPA is federal and Minnesota is the MN Pollution Control Agency. They are concerned about the environment and what we are throwing in the regular trash or sending into the sewer. The 7 county metro do their own inspections enforcing MPCA rules.
Some things they look for:
- Proper labeling on hazardous waste containers
- Amalgam separator documentation
- Weekly inspection logs
- Chemical indicator documents
- Black pharmaceutical hazardous waste containers
Minnesota Board of Dentistry is well known by all dental professionals since they provide us with a dental license to do dentistry. Some are not aware that Board rule requires us to follow the most current CDC Guideline for Dental Healthcare Setting as minimum standard for infection control. Even though CDC is a non-regulatory agency the guide becomes regulatory through Board rule. Their primary concern is the public (our patients). So anything involving the patient is CDC or the MN Board of Dentistry.
To name a few:
- Spore testing at least weekly on all sterilizers
- Cold Sterilization/Disinfectant – monitor for effectiveness
- Chemical indicators both inside and outside of all packages
- Dental unit waterlines – treat and monitor with testing
- Emergency kits – monitor expiration dates
- License and Renewals posted public view
- Wearing name tags
Minnesota Department of Health is an agency most every dental office has been inspected by. It is their radiation rule we follow. Regardless if the office is digital or traditional for x-rays we still need to have an x-ray protocol.
Besides routine test:
- Fog test
- Mesh/Screen test
- Program audit
- CBCT Utilization report
- Apron integrity check
- Shielding/Survey Plan
We also need a standing order signed annually by all dentists of the practice, training upon employment or a change in the office as well as protocols on how we handle pregnant employees/patients, apron policy and who’s allow to take x-rays.
As you can see we need to be well versed on many more agencies or we may be at risk. Having great recordkeeping will prove we are doing what is required – If it is not written down it didn’t happen. Great documentation and site specific written protocols will keep us out of jeopardy, keep our patients safe along with a safe work environment for our employees.
Leanne M. Mathieu Kramer, LDA, CDA, CDPMA
- Authorized OSHA Outreach Trainer – General Industry
- Independent Compliance Consultant