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Is a sharps container required in each Dental Office operatory?

 

To be compliant with OSHA guidelines, the answer is yes! Clinical employees should be disposing of soiled sharps in all operatories “at the point-of-use”. All used sharps (needles, carpules, damaged instruments and extracted teeth) which are contaminated with blood or saliva should be treated as if infectious. Sharps containers in your dental operatory should be part of your Engineering Controls and Work Practices per OSHA’s Blood Borne Pathogens Standard.

Not only are sharps containers required in each treatment room, so are small red bags. The logic here is to reduce the re-handling of any type of soiled waste, be it soft or sharp. It makes sense, disposing of soiled waste at the point-of-use immediately reduces the risk of infection and injury to the employee.

 

So, it becomes clear: employees cannot walk around or re-handle any soiled waste. Taking this into consideration, how do we accomplish this end without creating countertop clutter? Let’s face it, no one wants do have ugly red containers screaming biohazard in their operatories. Most times we want our ops to be relaxing and serene as well as aesthetically pleasing. We don’t want them to look clinical and potentially infectious, reminding patients of an uncomfortable hospital setting or worse. In recent years, dental offices have gone to great lengths to create the feel of a “day spa” not a biohazard wasteland.

 

How can we be compliant without sacrificing a peaceful, calm, aesthetic environment? While these sharps containers (and small red bags) do need to be present in the ops, they don’t need to be visible. Placing them in a cupboard is an easy way to keep employees safe and keep your operatory looking pretty. Another alternative is to have custom-cut, drop down disposal portals designed into your countertops. (Speak to your dental supplier to get a quote on this aseptic dental operatory feature).

 

So, the advantages are clear. So is the law. If you have not yet done so, make sure you place a small sharps container and red bag in each of your treatment rooms. The benefits outweigh the risk. Just do it!

 

Written by Jill Obrochta and Heather Whitt of Dental Enhancements

 

 

 

 

Dental office: OSHA Compliance– Do You Want to Pull Your Hair Out?

If you are in charge of, or in any way responsible for the OSHA Compliance Program within your Dental office, you know the tasks can be overwhelming, intimidating and at the very least daunting.

In 2013, the OSHA Compliance Requirements got even more cumbersome with the new mandate to have your entire team trained in Global Harmonization System (GHS) by the December 1st, 2013 deadline.  So now there is Annual Employee OSHA Training, GHS Proof-of-Training & required paperwork PLUS… having to have your facility completely in OSHA safety compliance.  It’s crazy!  But don’t give up!

 

A really good OSHA Compliance Program should consist of (3) Components:

  1. Annual OSHA Employee Safety Training
  2. Required Paperwork:  For each employee and updated written standards within your OSHA Manual
  3. Facility Safety to reflect all OSHA Safety Standards

 

Don’t be fooled by the “lunchtime free OSHA training” offered by some charismatic characters.  While the conversation may be informative, the OSHA Safety Facility Credentialing and required OSHA paperwork (both employee required forms, as well as an updated OSHA Manual) is key! 

 

If you need a complete Annual OSHA Employee Training solution, look for a trainer or training company who will provide you the “trifecta”.  The (3) components listed above neatly organized into a training package will be the key to your success.

 

Don’t be lulled into a false sense of security.  Go trifecta. That’s the winning ticket!

 

Written by Jill Obrochta & Heather Whitt of Dental Enhancements.

 

Top 5 OSHA compliance requirements for your dental office……

Do you consider your dental practice OSHA inspection ready? If so, congratulations!

If you are more like the rest of us, here are some tips that may help you out.

1.   Is your OSHA manual up to date?

Even if your manual is less than 1 year old, it may not be up to snuff to OSHA requirements. If your OSHA manual is Global HarmonizationSystem (GHS) Compliant, you are in great shape! Otherwise, it is time to get the latest OSHA manual that is compliant to the new Global Harmonization System Standard.

 

2.   Have you fulfilled your Annual OSHA Employee Training requirement?

YES! We are supposed to train annually. Every U.S. business has to. You are not alone with regard to this requirement.

 

3.   Is all of your OSHA Required Paperwork completed and organized?

This includes proof of annual training, GHS proof of training, employee occupational exposures (categorized, rated and in written form), Hep B vaccination records on file, and employee medical histories on file.

 

4.   Have you fulfilled your Global Harmonization System (GHS) Training Requirement?

Dental Offices’ deadline to complete training was on December 1st 2013. This training focuses on the international change regarding our hazard communication system and how we handle professional products and chemicals in the workplace. There is now an international standardized system to follow. Our MSDS sheets (USA) will change to SDS sheets (International) and our labels will change from Hazardous Rating Labels (colored, lettered, numbered) to Pictograms which need to be learned and memorized by employees as part of your training program.

 

5.   Is your facility OSHA compliant?

There are many areas inspectors will check in your dental office, ranging from proper handling of soiled waste and sharps to sterilization logs and receipts. Try to find an OSHA compliance training company that will offer an in-depth facility credentialing and report. A company that will work with you to not only provide the report, but also the recommendations to rectify any non-compliant areas. The 72-Point OSHA Safety Facility Report from Dental Enhancements is based on the last 15 years of dental office OSHA fines and their OSHA experts help you correct any non-compliant areas once they customize and complete your report. It’s awesome!

 

If you are confident and comfortable with your current compliance position, that is terrific. If you feel you are lacking, a reputable OSHA compliance training program would be well worth looking into.

 

Compliance is a requirement, not voluntary. Make sure your program is comprehensive. You don’t want to spend an extensive amount of time with the OSHA Inspector, do you?

Written by Jill Obrochta and Heather Whitt. Contact us today if you need help and advice Dental Enhancements

 

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Splatter vs. Saturated- What Goes in the Red Bags?

There seems to be a big debate……..What soiled waste should we dispose of in the red bags?

First of all, it’s important to note that soft soiled waste needs to be disposed of at the point of use. For a dental office, this means keeping a small red bag in each operatory. And this OSHA safety requirement really does makes sense because it forces the clinician to handle the soiled waste less. Ultimately limiting the possibility for more exposure to the infectious waste. Small red bags then need to be sealed or fastened shut before walking them to the big red bag container for final disposal.

Now back to the big debate…..What do you put in your red bags: Splattered or Saturated Waste?

According to OSHA’s own definition:

 “ALL PROCEDURES INVOLVING BLOOD…  or other potentially infectious materials shall be performed in such a manner as  to minimize splashing, spraying, splattering, and generation of droplets of these substances.”

But then, OSHA defers to whatever the Center for Disease Control (CDC) recommends. CDC has not changed their definition of Biomedical Waste since 2003. Their definition reads as follows:

Regulated medical waste requires special storage, handling, neutralization, and disposal and is covered by federal, state, and local rules and regulations (6,297,300,301). Examples of regulated waste found in dental-practice settings are solid waste soaked or saturated with blood or saliva (e.g., gauze saturated with blood after surgery), extracted teeth, surgically removed hard and soft tissues.

This definition becomes rather antiquated and potentially dangerous when you think of the disease changes (with regard to Hepatitis C and D) and permitting your dental team to dispose of these items in the common trash.

Four States have smartened-up and have changed their State Regulations to mandatory “Disposal of Splattered Waste” into facility red bags. These four States are: Arkansas, Maryland, Utah, West Virginia.

You may want to implement this “Disposal of Splattered Waste” at your dental office, even though it is not State mandated. It makes sense. Have you ever dropped a bib clip or pen into the trash and had to dig it out? Digging it out typically requires digging through 5-10 patient’s soiled waste. Is that something you want your team exposed to on a daily basis?

Be smart. Have a staff meeting and discuss what splattered items you will put inside of your red bags going forward. While for most States, the Federal Law continues to defer to red bag disposal of “Saturated Waste”, the prudent, professional and most protective practice is to start disposing of all “Splattered Waste” into your point-of-use red bags.

Splattered Waste Disposal is in the bag! It’s hip, it’s safe, it’s the right thing to do.

Written by Jill Obrochta and Heather Whitt of Dental Enhancements

Business Associates Agreements- Who the Hell Needs to Sign These?

 

In 2013, HIPAA brought sweeping changes for all healthcare facilities to implement. Not only does your staff need to be trained to the new HIPAA Omnibus Rule standards, but now protecting your patient’s PHI (Protected Health Information) is much more far-reaching. Under these new HIPAA Omnibus Rules, employees, as well as vendors need to sign confidentiality agreements. Requirements for vendors will vary. It’s important to know who needs to sign these new confidentiality agreements called Business Associate Agreements. The law is tricky because it is written in two different ways and you want to be sure to cover yourself for both translations.

First, HIPAA Omnibus Rule clearly states that you must have a Business Associate Agreement signed “by any company that collects patient data from your office”. For example: collection agencies, IT technicians, confirmation services, consultants, etc.

The next translation is the tricky one: HIPAA Omnibus Rule also states “that your office is responsible to protect the handling of all patient’s PHI. (Protected Health Information).” There are 18 common Protected Health Identifiers: Name, address, phone number, email address, zip code, birthdate, social security number, credit card number, to name a few. This means that your office should distribute and seek  signatures (on Business Associate Agreements), for all vendors or subcontractors that may see or use your patient’s PHI in the course of doing business with you.

Examples would be: labs, temporary employees, and after hours services. While this area of the HIPAA law may be interpretive, it’s better to do your due diligence and have these signed documents on file rather than not.

There are some exceptions though (thank goodness, the government is giving us a break here). It’s considered the “Course of Doing Business” when you communicate with Doctor’s Offices, Insurance Companies and Pharmacies. No need to have a Business Associate Agreement signed for these day-to-day interactions. Also, Delivery Services are considered “conduits” and they are exempt. Conduits are typically bonded and insured. Examples would be: Fedex, USPS, and UPS.

So how will you tackle this project of getting a Business Associate Agreement and keeping track of them? Make sure you choose a HIPAA Solutions Company that provides ready-made forms, logs, and telephone assisted guidance to help you with this arduous task. A complete solution that includes:

  •  A new HIPAA Manual (written to the new Omnibus Rule)
  • CD-ROM (with employee training video and all of the electronic forms)
  • 30 minutes of telephone assisted guidance from a HIPAA expert

HIPAA Omnibus Rule Complete Package is a winner when undertaking this task.  HIPAA Omnibus Rule is hard enough, don’t go it alone! Now you know “who the hell has to sign these things.” Now you just have to decide who the hell gets to oversee this lovely project within your healthcare facility.

 

Written Jill Obrochta and Heather Whitt of Dental Enhancements

 

TEXAS HIPAA HB300: WHAT’S IT ALL ABOUT?

HB300—No, it’s not a new “South-of-the-Border” tequila you must try, but you really must have HB300 if you are a healthcare provider in Texas…

In 2012, Texas– Governor Rick Perry mandated a law that holds all Texas healthcare providers to stricter understanding, handling and protection of patient PHI (Protected Health Information).

Texas House Bill 300 requires all healthcare providers in Texas to deliver patient requested records in less time  (15 days instead of the Federal Standard of 30 days).  If you do not comply the fines can be exorbitant–Fines: $5000-$250,000 & Class B Misdemeanor–PLUS:  Daily fines that can accumulate  for breaches without reporting to the patient within 30 days.  This also means that if the patient has an outstanding balance with you, and you want to withhold their records until they “pay-up”, you may be now setting yourself up for an expensive visit from a Texas HIPAA Auditor. A Best Business Practice Policy in Texas now would be to:  Release the patient records within 15 days of written request, collect on patient balances later!

Texas HB 300 also requires that much more HIPAA Paperwork be in place within your work dwelling. You will need to have each employee be HB300 Certified within 60 days of hire and then every two years update that certification with training and written proof-of-the-training.  Specific in-house policies need to be written and in place within your HIPAA Manual  as they apply to:  your handling of patient PHI and ePHI (electronic Protected Health Information), your office internet and computer protection policies, and your safeguards for all patient PHI and ePHI.

Don’t get overwhelmed.  Instead, look for a comprehensive training program that will provide you with:  Employee Training, Employee Certification, Required HB 300 Written Policies and if you have not updated your HIPAA Manual, you will want to get one updated to the new Federal HIPAA Omnibus Rule Standards by investing in a complete Federal  HIPAA training solution to this new standard.

So Texas, make sure you have these (3) HIPAA solutions:

  1. HB 300 Employee Training & Certification due in place since Sept 2012
  2. Updated HB 300 Employee Training & Certification update for 2014 due in place by Sept 2014
  3. HIPAA Omnibus Rules & Employee Training due by Sept 23, 2013

Don’t wait until the Texas HIPAA Auditors “come a-knockin on your door” for their bounty.  You don’t want to pay this price, do you?

Written by Jill Obrochta, HIPAA Trainer for Dental Enhancements

 

 

HIPAA Compliance – NOT an Option

 

There is a common misconception in the dental office workplace.  Most dental offices have implemented HIPAA regulations back in 2003 and feel their efforts are sufficient.  This could not be farther from the truth!

In March 2013 Federal Regulations concerning HIPAA in the Healthcare Workplace all changed.  The new HIPAA Omnibus Rules require employee training (for all team members), a new HIPAA manual (written to these new standards) and plenty of new policies and paperwork to implement.  All of these new regulations and protocols should have been operational within your dental office as of September 23, 2013.

The new HIPAA Omnibus Rule protocols are required by all healthcare facilities– there are no exceptions!  Why is HIPAA changing?  It is presumed that perhaps up to 70% of Identity Theft in this country could be leaked from a healthcare facility.  Protection of the patient’s personal information is foundational.  The new laws protect patient PHI (Protected Health Information).  There are about 18 common Protected Health Identifiers that all healthcare workers need to safeguard.  From paper to computer input to internet activity — all employees need to be trained on these new HIPAA Omnibus Rules and the new protocols need to be set in place

There seems to be a lot of confusion and misunderstanding surrounding HIPAA within the dental field.

HIPAA compliance is not voluntary or recommended– it is required!  The new HIPAA Omnibus Rules come with big fines ($10,000 – $1.5M) and a HIPAA Task Force is out doing audits to ensure that these new rules are properly in place.  This is a very serious and pressing issue.  Make sure you choose a HIPAA Omnibus Rule compliance solution that offers complete compliance.  Don’t ignore these new federal regulations.  Don’t give Mr. HIPAA Auditor reason to hit you with those big fines!  Do you have your HIPAA Omnibus Rules in place? Get your groove on!

Written by Heather Whitt, HIPAA Trainer for Dental Enhancements

Dental Office OSHA and HIPAA Compliance since 2013

There are really 3 things you should put on your “must do” list for your dental office OSHA & HIPAA requirements in 2013. These are the (3) Requirements:

  1. Annual OSHA Employee Training
  2. GHS: Global Harmonization System Proof of Training
  3. HIPAA Omnibus Rule Employee Training & Implement Protocols

1. Schedule your Annual OSHA Employee Training….Now!

Too many times the busy pace in a dental office makes it easy to forget annual training obligations. The best way to ensure you keep in compliance with your annually required training is to work with a company that will send you reminders, or better yet, schedule your next year’s training, at the time of this year’s training! We do it with hygiene re-care patients, why would we not do it with something as important as a federal requirement! Dental Enhancements coaches will train and track your required OSHA trainings with phone call reminders, emails and postcards. But it’s safest and best to just always schedule your next training, at your current year’s training. That way your office will remain in healthy shape….just like teeth and gums in re-care!

Also Get a Facility Report that Reflects How OSHA Compliant Your Dental Office Is….

Having an OSHA Employee Training Session is only half the battle. If you do not keep your facility up to safety standards the fines can be serious and expensive! Make sure you choose to work with an OSHA coaching service that will either come to walk-through your facility or review all of the physical safety statutes associated with a dental office within your State. Dental Enhancements provides a very comprehensive 72-point Facility Checklist. It is completed over the phone with one of your employees and a post-evaluation report is instantly emailed to your office so you can review where you may be remiss with OSHA Safety. Best part: You can call the OSHA coaches at Dental Enhancements anytime if you need help with understanding how to get the non-compliant items rectified. It’s like having a private tutor for your OSHA homework!

 

2.  OSHA this year will have you adding one additional Employee Training called GHS: Global Harmonization System.

The USA will join world-wide efforts to control hazardous chemical handling in the workplace with one unified system This will affect your MSDS Sheets, as they will change to SDS—universal sheets and need to be stored in (2) formats (paper and cloud-back-up). Chemical / Professional Product labeling will be effected too. Proof of GHS Training for all dental employees will be required as of December 1, 2013.

 

3. Research & Get Educated on the New HIPAA Omnibus Rule Laws

As of March 2013 there are new HIPAA Laws called the Omnibus Rules or the Final Rule: HIPAA law makes did a complete overhaul of the existing HIPAA laws in an effort to reduce Identity Theft emanating from within healthcare facilities. The Omnibus Rules are 580 pages in length. If you want a cleaner condensed version for immediate use within the dental office environment, try the HIPAA Omnibus Rule Complete Package from Dental Enhancements. It will give you everything you need to learn and implement these cumbersome protocols, easily, in your dental practice.

As one of the countries few dental OSHA & HIPAA experts, I get calls all of the time asking for help with OSHA & HIPAA requirements. It’s my pleasure and passion to take the cumbersome burden of OSHA & HIPAA requirements off of a busy dental team’s plate. With 25 years of OSHA & HIPAA training experience, I can act as an extended team member to get these requirements in order with very little work effort needed from the team. Unfortunately, many of these calls come “too late”, when inspectors have already visited the dental office and have begun to sanction fines and warnings. Don’t be one of the slackers! It’s so easy to keep up-to-date and in compliance with your OSHA & HIPAA requirements, if you choose a dedicated, caring expert.

DentalEnhancements.com has been my home base for coaching thousands of dental offices all over the USA for the past 15 years. They offer better than ready-made manuals and training, as everything from Dental Enhancements is custom-made (including all needed employee forms—addressed specifically to each of you employees!) and “by-appointment” private team webinars to fulfill your annually required OSHA Employee Training.