By Terri J. Soules
Congratulations on earning the title of Safety Manager. You may have requested this promotion or more likely someone elected you for this position. Either way, it is a prestigious title and one that should not be taken lightly. Your responsibilities as safety manager are extremely important to everyone that enters your office, including yourself, your team members, your doctors, and the patients you serve.
As safety manager, your responsibility is to assist the practice owner in achieving compliance of various laws and regulations governed by Occupational Safety and Health Administration (OSHA), Centers for Disease Control (CDC), Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA), and any local agencies that may have jurisdiction in your area.
Regulatory compliance describes the goal that corporations or public agencies aspire to achieve in their efforts to ensure that personnel are aware of and take steps to comply with relevant laws and regulations. The scope of regulation ranges from specifying who may engage in the practice of dentistry to the disposal of extracted teeth. Maintaining regulatory compliance is an ongoing process.
Developing and maintaining the policies can be time-consuming and intense. Scheduling appropriate time in your schedule, rather than leaving it on a to-do list for no-show appointments, is highly recommended. Outsourcing your compliance needs is a great way to reduce the stress and time spent on developing the policies and insuring the training meets the proper requirements.
OSHA requires the following policies be “site specific” and updated annually or within 90 days of an OSHA standard release/revision.
Exposure Control Plan:
- Eliminates or minimizes employee occupational exposure to blood or other body fluids.
- Identifies employees occupationally exposed to blood or other potentially infectious materials (OPIM) in the performance of their regular job duties.
- Provides employees exposed to blood and OPIM information and training.
- Complies with OSHA blood borne pathogen standard, Federal Register 1910.1030.
- Identifies the hazards present that requires the use of personal protective equipment.
Personal Protective Equipment Policy:
- Aids in the selection of the appropriate Personal Protective Equipment for each task performed
- Outlines procedures to be taken when an occupational exposure to blood and/or OPIM has occurred
- Medical records on employees are to remain “confidential” and maintained for 30 years past the final employment date according to Federal OSHA (note: some states may require longer retention).
Hazard Communication Policy
- The purpose of the Hazard Communication Program is to “ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.”
Emergency Action Plan
- A workplace emergency is an unforeseen situation that threatens the employees, patients, or the public; disrupts or shuts down the practice; or causes physical or environmental damage. Emergencies may be natural or manmade and include (but not limited to) the following: floods, hurricanes, tornadoes, fires, toxic gas release, chemical spills, explosions, civil disturbances and workplace violence resulting in bodily harm and trauma.
Once the policies are in place, you must then train the employees. The new hire training will occur during orientation and then annually (within 365 days). The person performing the training must be qualified and knowledgeable in the subject matter. Training records must include the subject, trainer name and qualifications, signatures of the employees present and their job titles. The training records must be maintained for 3 years.
Some other aspects of being the safety manager include understanding the policies and being prepared to respond if an incident occurs that needs to be documented. The following is a small list of examples that would require your immediate attention: needlestick, exposure to blood, or OPIM, injury of any kind.
Noncompliance can be not only embarrassing but also expensive. Penalties can range from $600 for not establishing a written Exposure Control Plan designed to eliminate or minimize employee exposure, to $76,500 for not providing an injured employee with no-cost, post-exposure medical evaluation and follow-up, not testing the blood of the source individual, as required under OSHA's bloodborne pathogens standard, for not including the proper method of removing the capped needle from a syringe, or explaining procedures to be followed in the event of an exposure, not providing an opportunity for employees to ask questions about the training. Having an incomplete exposure control program and not updating and training annually.
For additional information on OSHA, click here:
- Olivia Wann, RDA, BS, Modern Practice Solutions, Quality Control Manual
- US Department of Labor, Occupational Safety and Health Administration, Regulations (29-CRF). Bloodborne Pathogens 1910.1030. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051
- International Sharps Injury Prevention Society http://www.isips.org