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Training & Personnel Archived Through 2012
 FAQ - Training & Personnel - 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?

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:

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:

http://www.osap.org/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: http://www.osap.org/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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