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Regulatory Archived Through 2012
FAQ - Regulatory - Archived Through 2012

 

 

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?

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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