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Q How long does an office need to keep records on hazardous waste pick up, laundry for gowns and all other records that OSHA requires? Our office uses self-contained water units by adec. We only use Culligan water. We are finding that there are not many water tests to choose from. I would like to know if the water test that we use would have to be one that has to be tested at a qualified lab or are the petri dish type ok that we test in the office?

Q It has come to our attention that we need a written policy for latex sensitive employees. Does OSAP have any guidelines for such a policy?

Q Eyewash stations with faucets that turn upward, can they be considered an eyewash station?

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Q How long does an office need to keep records on hazardous waste pick up, laundry for gowns and all other records that OSHA requires?

A OSAP is not in a position to offer legal advice. Because recordkeeping logs can be a legal issue and play a role in risk management, you should also consult with the dental practice's attorney and/or attorney knowledgeable in medical law. They can provide legal advice on maintaining such records, especially those concerning issues not covered under OSHA standards, other Federal regulations, or specific state laws.

OSAP can provide you with the following general information:

Our office uses self-contained water units by adec. We only use Culligan water. We are finding that there are not many water tests to choose from. I would like to know if the water test that we use would have to be one that has to be tested at a qualified lab or are the petri dish type ok that we test in the office?

OSAP does not recommend, endorse, nor promote products, however, we can provide you with general information concerning dental water line testing. Currently, we are not aware of any regulations that mandate dental unit water (DUW) be tested only through a qualified lab. Although that is an option, in-office testing is available to dental facilities.

The authors of From Policy to Practice: OSAP's Guide to the Guidelines state that you should consult the manufacturer of your dental unit or water delivery system to find out how to best maintain treatment water quality (less than 500 CFU/mL) and how often to monitor dental unit water. (1)

The Center's For Disease Control and Prevention's (CDC) Infection Control Guidelines for Dental Healthcare Settings also state that dentists should consult with the manufacturer of their dental unit or water delivery system to determine the best method for maintaining acceptable water quality (i.e., <500 CFU/mL) and the recommended frequency of monitoring. (2)

Monitoring the dental water quality can be performed by using commercial water-testing laboratories. Some laboratories provide specialized services to the dental profession, but any commercial water-testing lab can enumerate water bacteria present in a sample. Another option is to perform self-water testing using in-office test kits.

Further information on in-office water testing kits/testing samplers may be obtained from the following companies:

1. Millipore Corp.:

http://millipore.com/publications.nsf/docs/TB094

2. Micrylium:

http://www.micrylium.com/products.php?ID=18&col=pID

OSAP provides a great deal of information concerning dental unit waterlines, including links to additional resources. The information may be viewed at:

http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=24

OSAP's FAQ's concerning dental unit waterlines may be viewed at:

http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=26#waterquality

Additional information may be viewed at:

1) The United States Air Force Dental Evaluation & Consultation Service also provides information on DUW and products that may be viewed at:

http://www.airforcemedicine.af.mil/decs/

2) The American Dental Association has additional information that may be viewed at:

http://www.ada.org/prof/resources/topics/waterlines/index.asp

3) An excellent article, "Infection Control Report: Waterlines, Striving For Clean Lines", by Chris Miller, PhD appears in the September 2003 issue of Dental Products Report. This is a free monthly publication and the articles are also posted on their website.

To view the entire article to go: http://www.dentalproducts.net/xml/display.asp?file=1415

The dental products report is a free service, however, you must register first to gain access to the articles.

Resources:

1) From Policy to Practice: OSAP's Guide to the Guidelines. Published by OSAP.
Copyright 2004

2) CDC: Infection Control Guidelines for Dental Healthcare Facilities:
http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm

 

The Bloodborne Pathogens Standard 29 CFR 1910.1030 does state the following:

Medical Records: 1910.1030(h)(1)(iv):

The employer shall maintain the records required by paragraph (h) for at least the duration of employment plus 30 years in accordance with 29 CFR 1910.1020. (1)

Training Records: 1910.1030(h)(2)(ii):

Training records shall be maintained for 3 years from the date on which the training occurred. (1)

OSAP is not currently aware of any federal requirements for maintaining laundry records/logs for gowns. OSHA's Bloodborne Pathogens Standard 29 CFR 1910.1030 does not list this under recordkeeping requirements.

With regard to hazardous waste logs, should the office contract with a waste hauler, the office should be provided with a receipt of shipment (at time of pick-up) and manifest (several weeks later). Once the waste leaves the office the Environmental Protection Agency (EPA) regulations apply. All hazardous waste logs should be maintained for the length of time stipulated by your State and local Environmental Protection Agency.

You may also be interested in resources for waste management that may be viewed at:

https://osap.site-ym.com/displaycommon.cfm?an=1&subarticlenbr=72

http://www.deq.state.va.us/p2/mercury/documents/manual.pdf

The sterilization monitoring log record book should be used to record the results of biological monitoring, as well as, mechanical, and chemical process integrators. Sterilization monitoring log record books may be purchased (e.g. through the monitor's distributor/manufacturer, dental sales representative, etc.) or can be developed by the practice. Most dental practices choose to purchase a monitor record log book because they are simple to use and maintain.

Requirements, regulations, and recommendations do vary among states, therefore, records must be maintained long enough to comply with regulations in your state or locality. Sterilization monitoring requirements, including recordkeeping, can be regulated by the State Board of Dental Examiners/Licensing Board, through the State Health Department/Agency and/or through legislative law.

To determine if you are in a state with required recordkeeping regulations and requirements contact your State Board of Dental Examiners/State licensing agency, as well as, State Public Health Agency/Department.

There could be other state laws/regulations that we would not be aware of with regard to the length of time to maintain records/logs. Again, you should contact your State Board of Dental Examiners/Licensing Board, State OSHA Plan (should the practice be located in a state with their own plan), state/local Environmental Protection Agency (EPA) office, and state/local health agency (health dept.) for all applicable laws in your state.

OSAP provides links to state agencies that may viewed at: https://osap.site-ym.com/displaycommon.cfm?an=1&subarticlenbr=71

Resource:

1) OSHA's Bloodborne Pathogens Standard 29 CFR 1910.1030

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

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Q It has come to our attention that we need a written policy for latex sensitive employees. Does OSAP have any guidelines for such a policy?

A OSAP would like to refer you directly to the Centers for Disease Control and Prevention's Infection Control Guidelines for Dental Healthcare Settings. In part, the guidelines state the following:

Contact Dermatitis and Latex Hypersensitivity

Occupationally related contact dermatitis can develop from frequent and repeated use of hand hygiene products, exposure to chemicals, and glove use. Contact dermatitis is classified as either irritant or allergic. Irritant contact dermatitis is common, non-allergic, and develops as dry, itchy, irritated areas on the skin around the area of contact. By comparison, allergic contact dermatitis (type IV hypersensitivity) can result from exposure to accelerators and other chemicals used in the manufacture of rubber gloves (e.g., natural rubber latex, nitrile, and neoprene), as well as from other chemicals found in the dental practice setting (e.g., methacrylates and glutaraldehyde). Allergic contact dermatitis often manifests as a rash beginning hours after contact and, similar to irritant dermatitis, is usually confined to the area of contact. (1)

Latex allergy (type I hypersensitivity to latex proteins) can be a more serious systemic allergic reaction, usually beginning within minutes of exposure but sometimes occurring hours later and producing varied symptoms. More common reactions include runny nose, sneezing, itchy eyes, scratchy throat, hives, and itchy burning skin sensations. More severe symptoms include asthma marked by difficult breathing, coughing spells, and wheezing; cardiovascular and gastrointestinal ailments; and in rare cases, anaphylaxis and death. The American Dental Association (ADA) began investigating the prevalence of type I latex hypersensitivity among DHCP at the ADA annual meeting in 1994. In 1994 and 1995, approximately 2,000 dentists, hygienists, and assistants volunteered for skin-prick testing. Data demonstrated that 6.2% of those tested were positive for type I latex hypersensitivity. Data from the subsequent 5 years of this ongoing cross-sectional study indicated a decline in prevalence from 8.5% to 4.3%. This downward trend is similar to that reported by other studies and might be related to use of latex gloves with lower allergen content. (1)

Natural rubber latex proteins responsible for latex allergy are attached to glove powder. When powdered latex gloves are worn, more latex protein reaches the skin. In addition, when powdered latex gloves are donned or removed, latex protein/powder particles become aerosolized and can be inhaled, contacting mucous membranes. As a result, allergic patients and DHCP can experience cutaneous, respiratory, and conjunctival symptoms related to latex protein exposure. DHCP can become sensitized to latex protein with repeated exposure. Work areas where only powder-free, low-allergen latex gloves are used demonstrate low or undetectable amounts of latex allergy-causing proteins and fewer symptoms among HCP related to natural rubber latex allergy. Because of the role of glove powder in exposure to latex protein, NIOSH recommends that if latex gloves are chosen, HCP should be provided with reduced protein, powder-free gloves. Non-latex (e.g., nitrile or vinyl) powder-free and low-protein gloves are also available. Although rare, potentially life-threatening anaphylactic reactions to latex can occur; dental practices should be appropriately equipped and have procedures in place to respond to such emergencies. (1)

DHCP and dental patients with latex allergy should not have direct contact with latex-containing materials and should be in a latex-safe environment with all latex-containing products removed from their vicinity. Dental patients with histories of latex allergy can be at risk from dental products (e.g., prophylaxis cups, rubber dams, orthodontic elastics, and medication vials). Any latex-containing devices that cannot be removed from the treatment environment should be adequately covered or isolated. Persons might also be allergic to chemicals used in the manufacture of natural rubber latex and synthetic rubber gloves as well as metals, plastics, or other materials used in dental care. Taking thorough health histories for both patients and DHCP, followed by avoidance of contact with potential allergens can minimize the possibility of adverse reactions. Certain common predisposing conditions for latex allergy include previous history of allergies, a history of spina bifida, urogenital anomalies, or allergies to avocados, kiwis, nuts, or bananas. The following precautions should be considered to ensure safe treatment for patients who have possible or documented latex allergy: (1)

Be aware that latent allergens in the ambient air can cause respiratory or anaphylactic symptoms among persons with latex hypersensitivity. Patients with latex allergy can be scheduled for the first appointment of the day to minimize their inadvertent exposure to airborne latex particles.
Communicate with other DHCP regarding patients with latex allergy (e.g., by oral instructions, written protocols, and posted signage) to prevent them from bringing latex-containing materials into the treatment area.
Frequently clean all working areas contaminated with latex powder or dust.
Have emergency treatment kits with latex-free products available at all times.
If latex-related complications occur during or after a procedure, manage the reaction and seek emergency assistance as indicated. Follow current medical emergency response recommendations for management of anaphylaxis. (1)

The authors of Infection Control & Management of Hazardous Materials for the Dental Team state that provision of dental care for a latex allergic patient should be done in an environment with latex as low as reasonably possible (known as ALARP). The following will help the dental team achieve this:

1) Provide treatment in a specially prepared room as the first patient of the day.

a. Staff members are not to wear latex while preparing treatment room.

b. Staff members are to handle all items that will contact patient with nonlatex gloves.

c. No one who has worn latex gloves that day should enter the treatment room.

2) Minimize previous contact of patient care items with latex-containing materials.

3) Prevent latex from directly contacting the patient during treatment (use latex alternatives).

4) Eliminate patient exposure to airborne latex protein in glove powder.

5) Have dental team members wear non-latex-containing items that may contact the patient.

The Centers for Disease Control and Prevention's (CDC) Oral Health Division provides additional latex allergy information for dentistry, including patients. The information may be viewed at:

http://www.cdc.gov/oralhealth/infectioncontrol/faq/latex.htm

The CDC provides further information at:

http://www.cdc.gov/search.do?action=search&queryText=Managing+dental+patients+with+latex+allergies

The Institute for Occupational Safety and Health (NIOSH) provides information that may be viewed at: http://www.cdc.gov/niosh/topics/latex

The American Dental Association (ADA) has information that may be viewed at:

http://www.ada.org/public/topics/latex_allergy_faq.asp

http://www.ada.org/public/topics/latex_allergy.asp

OSAP provides links to other latex information at: OSAP links: http://www.osap.org/displaycommon.cfm?an=1&subarticlenbr=314

Additional resources include:

Latex Allergy Resources: Links For Dentistry: http://www.latexallergylinks.org/dental.html
American Latex Allergy Association (List Of Latex Free Dental Products): http://my.execpc.com/~alert/dentalprod.html
Pub Med Abstract: http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=12572185&dopt=Abstract
Resources:

1) CDC: Infection Control Guidelines for Dental Healthcare Settings:
http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm

2) Infection Control & Management of Hazardous Materials for the Dental Team, 3rd. Edition. by
Miller & Palenik. Elsevier/Mosby Publisher. Copyright 2005.

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Q Eyewash stations with faucets that turn upward, can they be considered an eyewash station?

A Because dental offices utilize materials deemed hazardous (refer to each chemical/dental materials MSDS) offices must be equipped with emergency eyewash stations for use by all employees including handicapped employees who may be exposed to injurious materials.

OSAP can provide you with general information concerning eyewash station requirements as they relate to OSHA”s Hazardous Communication Standard (Hazardous Chemicals).

In addition, if the practice is located in a state with a state operated OSHA there may be additional eyewash requirements that OSAP would not be aware of. Therefore, the practice should also contact their state OSHA, if applicable, for specific eyewash station requirements in their state.

States without state operated OSHA plans must adhere to Federal Standards. OSAP would like to refer you directly to the Federal OSHA Standard that applies to emergency eyewash stations.

Based on ANSI requirements, it should be noted that the employee (who may be partly blinded by chemicals in the eyes) should be able to reach and use the eyewash equipment within appproximately10 seconds. If an employee accidentally turned on hot water to the emergency eyewash equipment it could result in further injury to the eyes, therefore, the eyewash should be a style, or installed in a manner, that by-passes the hot water line. The employee should be able to simultaneously flush both eyes. In addition, each eyewash station location should be designated by a sign/poster.

ANSI Z358.1-1998:
This national consensus standard provides details on emergency eyewash and shower equipment. The basic requirement is to have emergency showers and eyewashes within 10 seconds travel distance of a hazard.

ANSI Z358.1-1998
This requires that flushing fluids shall be tepid. make sure that supplied water temps are in the range of 60°-90° F. Personal eyewash equipment ,such as squeeze bottles, do not meet the requirements of plumbed or self-contained eyewash equipment. Make sure units meeting ANSI Z358.1-1998 are within 10 seconds of travel time from hazard time.

ANSI Z358.1-1998 EMERGENCY EQUIPMENT PERFORMANCE SPECIFICATIONS:

For Eyes:
Eyewashes:.4 GPM for a minimum of 15 minutes
Nozzles protected from airborne contaminants provide flushing fluid to both eyes simultaneously at a velocity low enough to be non-injurious. Simple operation: "off" to "on" in 1 second or less.
Height from standing surface 33" to 45".
Nozzles located 6" from nearest wall or obstruction
Minimum operating pressure: 30 psi.
Hands-free operation once activated.

A log shall be maintained and posted by eyewash stations indicating testing date and individual.

Because of the wide variety of eyewash equipment, OSAP would not be in a position to determine whether or not an eyewash station meets all of the requirements. However, we can provide you with the following additional information and resources.

Paragraph (c) of OSHA (Occupational Safety & Health Administration) Standard 29 CFR 1910.151. The OSHA requirements for emergency eyewashes and showers, found at 29 CFR 1910.151(c), specify that "where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use." As the standard states, an eyewash and/or safety shower would be required where an employee's eyes or body could be exposed to injurious corrosive materials.. OSHA refers to the requirements with respect to highly corrosive chemicals contained in the American Standard for Emergency Eyewash and Shower Equipment ANSI Z358.1-1998. (1)

OSHA Standard 29 CFR 1910.151(c) is available at:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9806&p_text_version=FALSE#1910.151(c)

According to OSHA, 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. ANSI's standard also provides detail with respect to the location, installation, nature, and maintenance of eyewash and shower equipment. (2)

If OSHA inspects a workplace and finds unsuitable facilities for quick drenching or flushing of the eyes and body, a citation under 29 CFR 1910.151(c) would be issued. When determining whether the eyewash or shower facilities are suitable given the circumstances of a particular worksite, OSHA may refer to the most recent consensus standard regarding eyewash or shower equipment, which would be the 1998 version of ANSI Z358.1, as well as other recognized medical, technical and industrial hygiene sources. (2)

Because OSHA utilizes the ANSI standards for emergency eyewash requirements, OSAP would like to refer you to the standards of the American National Standards Institute (ANSI). These standards are copyrighted, however, you may obtain copies of these standards by contacting ANSI at:

American National Standards Institute, Inc.
11 West 42nd Street
New York, New York 10036
Phone: (212) 642-4900

Resources:

 

(1) The Occupational Safety & Health Administration: http://www.osha.gov

The Occupational Safety & Health Administration has posted resources for dentistry at:
http://www.osha.gov/SLTC/dentistry/index.html

 

(2) The Occupational Safety & Health Administration: Standards Interpretation:

http://www.osha.gov/pls/oshaweb/owaquery.query_docs?src_doc_type=INTERPRETATIONS&src_anchor_name=1910.151(c)&src_ex_doc_type=STANDARDS&src_unique_file=1910_0151

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