OSHA hasn’t changed that much…

Okay, so every year, people go to big conventions and hear that OSHA has drastically changed and we have to do everything different.

That is rarely true, and isn’t true this year, either.

There are some changes in the hazard communication standard, but it’s nothing that’s a huge deal.  I’ll send y’all the new stuff in the next couple of weeks.  Just have your folks look over it, sign off on it, and you’re good.

Also, understand that I have worked in dental offices since 1989 and I know how a regular office works.  I want all of us to stay safe, avoid sticks, and avoid disease transmission, but I also know that we are ALWAYS in a hurry.  If I want people to perform procedures safely, I have to come up with ways that aren’t going to drive them nuts.  So every time there is potential for injury or disease transmission I tell folks to look at your office and find the best and safest way to do things in YOUR office.  Every office is not the same and OSHA and the CDC just want us to perform procedures as safely as possible for us and our patients in our own environment.

Here are the questions I have gotten this year.

One speaker said that buying multiparameter bags for our instruments aren’t sufficient.  We also have to put a separate indicator on the inside of the bag.  That is NOT true.  The multiparameter bags have a visible indicator on both the outside and inside of the bag to show that the instruments reached the proper heat for the proper amount of time.  (They test time, temp, and presence of steam).  If you don’t use multi-parameter bags, you may need to use the indicator strips, so buy the multiparameter bags and problem solved.

IN MOST STATES (in all of the southern ones for sure), empty/partially empty carpules do NOT have to be put into pharmaceutical waste containers and picked up.  They can go in the regular trash.  One speaker apparently stated that because our carpules contain epinephrine, that is a “P” list chemical and is dangerous so it has to be picked up.  That is NOT true.  In our case, Epi is mixed with lidocaine in one form or another, so it’s an epinephrine salt and is NOT a “P” list chemical.  So regular trash it is!  The only exception would be if you’re disposing of a bunch of it that’s expired…I wouldn’t throw all that away at once so you don’t freak anyone out. 

Finally, one speaker apparently said that you have to use a specific kind of closed, lockable container to transport instruments from the operatory to the sterilization area, and it must be done wearing big, impervious gloves.

That is somewhat true.  However, OSHA never requires a certain product.  Ever.  Here’s the deal.  They want instruments in a closed, labeled, container (with a lid that stays closed) so if you fall, you won’t fall on the instruments, or they won’t fly down the hall and stick someone else.  Any closed container that will stay closed and prevent you from being stuck and also prevents you from dripping goop on the floor is sufficient.  There are covers that snap onto bracket trays that suffice.  Or you could put a cassette or the instruments in a tupperware container with a closable lid and a biohazard sign on the container.  (Instead of labeling those containers, you can also write biohazard with a red sharpie and make sure everyone knows that those containers are filled with dirty instruments.  Then note the training.)     The 2003 guidelines say this: Instruments should be placed in an appropriate container at the point of use to prevent percutaneous injuries during transport to the instrument processing area. So whatever works.  And I disagree that you absolutely have to wear the big impervious gloves during transport…you’re not processing the instruments, you’re transporting them in a closed container which isolates you from the sharp instruments. (Sugar, if you somehow get stuck walking with a closed, locked down container, maybe sharps ain’t for you…)  Before you remove the instruments in the sterilization area for processing, put on your big impervious gloves.  Think about it…in the operatories, you don’t wear big gloves while performing a procedure, it’s only while you’re processing and handling the contaminated instruments that you do.  Use your good sense and use care when handling instruments to prevent sticks.  Period.  

Next question:  Do you have to take jackets off any time you leave the operatory?  I know that no one will do that because of time constraints, but should we? 

The infection control standard specifically says that ” All PPE should be removed before DHCP leave patient-care areas.”   The Bloodborne Pathogens standard says “All personal protective equipment shall be removed prior to leaving the work area.”

Most offices interpret that to mean you wear PPE in the back only (operatories, sterilization area, lab area), and the back of the office basically goes to the front desk, but not beyond it.  That makes sense.  That allows you to walk patients to the front for dismissal without removing your jacket, so long as you stay out of the front desk area and don’t touch anything/anyone. 

So, realistically, that means you should only wear your jackets in the back, don’t hang out in the front office with it on, don’t wear it out of the office, and definitely don’t wear them to lunch. Have a place in the back you can hang your jacket, don’t just throw it over a chair or on a counter. The good news is that bacteria doesn’t just fly off of jackets, so unless you rub your jacket on someone or something, or lick it, you’re generally okay.  However, if you’re going to touch/hug someone at the front desk, or you’re going to go into the front desk area for some reason, make sure your jacket is off.

Hope that helps!  You can always email me at [email protected] if you have a question.