Welcome to today's training video provided by Doctors' Management. This training video was designed to provide you with a comprehensive overview of health and safety regulations to ensure your practice fulfills the requirements established by the Occupational Safety and Health Administration. Doctors' Management is a full-service consulting firm that helps physicians and healthcare professionals increase profits and productivity, mitigate compliance risks, and reduce stress for providers and staff. OSHA and HIPAA compliance is just one of the service lines we offer to assist practices by simplifying the business of medicine. Before we begin, there are some recent updates for 2024. A final rule was issued and became effective January 1, 2024. This rule applies to establishments with 100 or more employees in high-hazard industries to electronically submit information from their OSHA reporting forms. OSHA's partial exemption extends to most medical and dental practices, which means these facilities do not have to maintain the 300 or 301 forms on a routine basis. However, all employers must report to OSHA any workplace incident that results in a fatality, inpatient hospitalization, amputation, or loss of an eye. Penalty limits are reviewed annually, and the agency has continued to adjust the maximum penalties for inflation. Penalties are assessed based on the type of violation, and the new limits reflected here became effective January 16, 2024. While OSHA's regulations may seem overwhelming, and there is an abundance of information, our goal is to provide you with relevant information to support your practice in OSHA compliance. Your presenter for this training is Kelly Ogle. Kelly received her Bachelor of Science in Dental Hygiene and her Master's degree in Organizational Psychology. Kelly has over 20 years' experience in health care and has presented for numerous organizations. She has conducted OSHA and HIPAA training and performed mock audits for hundreds of clients throughout the U.S. Kelly will begin the presentation with an agenda and comprehensive overview of health and safety regulations before diving into the specific standards affecting health care. You may pause the training video and resume as needed. Now, let's begin. The agenda for today is OSHA Background, Bloodborne Pathogens, General Safety, Emergency Evacuation or the Emergency Action Plan on how you get out of the office if there's an emergency or even how you stay in and protect yourselves. And then there's hazardous chemicals, and we'll talk about SDS sheets and creating your chemical list. Then you have ergonomics, workplace violence, and airborne diseases such as tuberculosis and now, of course, COVID-19. As part of OSHA's background, it is called the Occupational Safety and Health Act or Occupational Safety and Health Administration. It was presented in 1970 and put through United States Congress with the help of President Richard Nixon that wanted to create a national public health agency dedicated to the basic proposition that no worker should have to choose between their life and their job. The General Duty Clause is a clause that I like to call the Umbrella Clause. Each employer shall furnish to each of his employees employment in a place of employment which are free from recognized hazards causing or likely to cause death or serious physical harm to his employees or her employees and that he or she shall comply with the occupational standard promulgated under this act. What this means is they must follow the rules and regulations that OSHA puts forth to make sure that their employees are safe and also to provide you a safe and healthy workplace to work in. When I say the Umbrella Clause, what I said earlier is because if there are any things that don't have a regulation with them specifically, then they can find you under the General Duty Clause. For example, the two that they go by are workplace violence and ergonomics, so they don't have really a regulation on it or a standard that's written out for it, so they kind of put this under what would be called the General Duty Clause. This is a picture of your OSHA poster. If you live in a state and work in a state that has their own OSHA program, you will need to have your state OSHA poster posted. What that means is it may have a few different words in there that cover you as far as your state. Each state that has their own OSHA program essentially follows the rules of the federal OSHA program, but if there are specific things in your state that they worry more about, and most of it has to do with construction, or there are a few states that it has to do with what we do, but very few. Most of them have to do with oceans, working on a boat, and those kind of things. Check into that with your local OSHA program, and you can call them and ask any questions that you need about your coverage as far as OSHA is concerned. The employee rights and responsibilities. These are all general rights and responsibilities, so they cover everybody. It doesn't matter who you are, where you live, or anything. Your rights as far as an employee are to have a safe and healthy workplace and to have those hazard controls put there so that if there are, this even includes things like having a fire extinguisher or having something for you to control a hazard, is essentially what that is. Your information and training, so information on any hazards that may be in the office or things that you may have to do to avoid those injuries. Training on safety, it is required through OSHA to have yearly training, whether that's 15 minutes, whether that's an hour and a half. It all depends on how big your office is, if there are any injuries or anything that happens or occurs that you need to go over more frequently. It's all going to depend on you as far as your facility. Medical treatment, the employee has the right to medical treatment if they've been injured on the job. This can include a needle stick, this can include a fall. You also have the right to decline that medical treatment. You can access your personal medical records. Now these are medical records as far as you being an employee and your records as far as that. Your records as far as if you are seeing your physician that you work for as a personal doctor, you do not have the rights as far as HIPAA to get into your record. That's a stricter law by HIPAA that you are not supposed to get in records like that because you are a patient at that moment, not an employee. And so you can't access your own record. Request OSHA inspection, protection from job discrimination. Also responsibilities comply with the OSHA regulations, participate in the employer's safety program, attend training, report hazards, suggest controls, and report occupational illnesses and injuries. So when I was talking about your record, you don't cross the line of being a patient and an employee because, I mean, if you needed to access your personal medical record as far as you being seen in the office, you can get permission to see that, but to just access your records as an employee, or if you're, you know, on the job working, then you're not supposed to actually, and HIPAA would actually get, you know, you would get in trouble with HIPAA. So now OSHA inspections, enforcement, they usually will come unannounced. There's there's there, unless for some odd reason that they call you beforehand. We have one, we've had warnings before where an employee has left and said, I'm calling OSHA on you. So then they were able to get a little prepared for an OSHA inspection, but most of the time, it's a surprise inspection. It's not something that is, you know, they call you and say, hey, we're going to come down and look at your office. So it's based on priorities. Most of the time, it has to do with the danger to the employees and where they're working and their job responsibilities or tasks put them in danger, the fatality or catastrophe. Most of our offices don't come into that situation. It's usually because an employee has complained. That's usually why it occurs. Or there's a referral from another government agency, such as if someone were to come in and investigate something else and they saw that there was a danger to employees and their working environment, then they could call OSHA and report. So OSHA consultation services are free. If you have a state consultation service, you can call them up. Most states do. You can call them up or you can call federal OSHA and tell them that you want them to come out and do what's a mock audit. I do those for my clients. You can actually get them free through OSHA if you want OSHA to come and take a look at everything and see what needs to be done. And they will let you know. And it's just like a regular inspection. They go through everything, they let you know what's going on, and they let you know what to fix. So it can be scheduled. There's no fees, no fines. It's absolutely free to do that. If an inspection occurs, you need to be prepared. That's why that OSHA training is very important every year, and you go over certain things during that training to remind the employees these things so that they can remember them when asked. So the inspector will present their credentials, they'll explain what's going to happen. You don't have to worry about any kind of HIPAA breach or anything. They'll review any kind of written documentation, or they will, and they'll go over it with you, looking for records as far as vaccinations and things on employees. They'll interview the employees, and this is where it gets very important and why it's very important that you have your yearly training, is that they can ask questions about things that you may have or should have gotten trained on, and if you can't answer them, then the office is going to get in trouble for not training you properly. So, it's going to be the employee's responsibility to make sure that you learn these things and keep those on hand so that you're not caught off guard when the inspector asks you these questions. Also, giving an exit briefing, what they're going to do is they're going to kind of go through everything and explain everything to you and make sure that you understand it and, you know, on those things that you have to get fixed. The practice should accompany the inspector, be cordial and cooperative, and don't cancel your schedule if something comes up. Record what they record, recognize that OSHA inspection is not a HIPAA violation, and you just need to ask questions, be a part of it. If you're the one following them around, then make sure that you're being a part of that, that you are asking questions, writing notes, those kind of things. Now, unfortunately, if your inspection didn't go well, then you could receive a citation. You should receive this citation within several days after the inspection occurs, and when you receive it, you have to post it within your office or for three days, three business days, and it has to be visible to all employees because you're going to let them know what OSHA found. Now, you can appeal it. The employers must initiate the proceedings and writing within 15 days to appeal the citations or the penalties. However, you have to initiate an appeal within 10 days if you're wanting to contest the abatement date, which means the time that they gave you to fix everything. If you want to extend that time, then you will need to let them know. So OSHA penalties are based on complicated factors and formulas, reduced based on several factors. So I could not just say, oh, well, if you forgot to do this or you didn't do this, this is how much it's going to cost. I don't know that. What I have seen in the past is I have noticed that they give you the maximum penalty for serious or other than serious penalties. They give you that top number and then they will go down from there. So that's their starting point. So hopefully if you don't have a lot of employees, you have a small amount of employees that reduces it possibly 15 percent reduction. It's all going to depend on the actual inspector themselves. And then if you have past history, a good past history and good faith effort where you fix it, it's immediate. Maybe they've come out before and, you know, there was no problems found and they decided to come out again and they found something they're going to know that you were willing to work on it and get that fixed. So bloodborne pathogen standard. This covers all employees whose job responsibilities put them at risk for exposure to bloodborne pathogens. It was revised in 2001 and there was a new compliance directive that November. So January to November, they created the directive. Employees must have access to a copy of the standard and the written exposure control plan and also if you wanted a copy of the bloodborne pathogen, the actual standard, you have to have access to that. So employees are entitled to a copy provided free of charge within 15 days of that request. Bloodborne pathogens are microorganisms causing diseases in humans transmitted only through contact of infectious body fluids. This can include blood, semen, joint fluid, vaginal secretions, amniotic fluid, saliva and dental procedures, vitreous fluids in the eyes, mixture of fluids, urine, feces and vomit only if blood is present or visible blood is present. So bloodborne pathogens, we pretty much have to, if we are working anywhere around bodily fluids, that we have to protect ourselves. We can come in contact with some of these examples here, Hepatitis B, C, HIV, malaria, syphilis, Ebola virus, West Nile virus, these are just some to mention that we can come in contact with. So we have to protect ourselves wearing our gloves, gown, face protection, whatever we need to protect ourselves. So Hepatitis B, these are the ones that we generally come in contact with would be Hepatitis B, C and HIV. And those are the ones that are actually asked to be tested on through OSHA. So that's what your right is as an employee is to get tested for these. So the symptoms of Hepatitis B are jaundice, fatigue, abdominal pain, anorexia, nausea and vomiting. And then the transmission, sharps injury or splash, splatter or spill into mucous membranes or non-intact skin, which could be an opening in the skin. And then 1 million U.S. citizens have Hepatitis B and then 500 people die annually in the U.S. and a 5% chance of developing chronic infection. So the number is lower than Hepatitis C and HIV due to being able to have a vaccination. And carriers may never develop the symptoms but can transmit the disease and that goes along with all of these. So you have Hepatitis C, it's another virus that causes liver damage with the same or similar symptoms as Hepatitis B, fatigue and abdominal pain and transmission is the same all the way across the board whether it's Hepatitis B, C or HIV. And 3.5 million U.S. citizens have Hepatitis C and an 85% chance of getting chronic infection. So this one's higher and the reason why is there are medications but there are not the chances of getting a vaccination for this. And you can be, somebody can be asymptomatic for up to 20 years and actually pass it along to somebody. This is one of the leading causes for liver transplants and there is no vaccination, no immune globulin and there are, like I said, the medications are out, are getting better initially they were kind of toxic but they're getting better and helping a lot of people. With HIV, you've got 1.5 million people in the U.S. or more that actually have HIV and the rate of infection is increasing but the death rate is going down because we do have better drugs. This is transmitted through contact with contaminated body fluids. So the symptoms, swollen lymph nodes, weight loss, night sweats, opportunistic infections, skin lesions, may be asymptomatic for many years. No vaccine, no immune globulin, no cure. So vaccine is in clinical trials but it's still found to be ineffective. We know, we know how long it takes to get these vaccines put out. Methods of transmission, if you want to put that right, that is, methods of transmission in the workplace, splash, splatter, spill, sharps injuries, injections, IVs, surgical or dental procedures, invasive procedures, handling, cleaning contaminated items, also in the general community with sexual contact, sharing dirty needles, mother to fetus, and the baby through breast milk. Universal precautions. You have to treat, no matter what it is, whether it is airborne, whether it is blood-borne, whether it is any of those, you need to be prepared to be exposed if you are in the medical field. Whatever field or whatever specialty you're working in, be prepared to see patients that have something that you don't want to catch, and if we're doing that right, and we are covering ourselves like we should, then we don't need to worry about catching it. You know, as long as we're, I mean, there's going to be times that there's going to be a rip in a glove or a needle stick injury, but if we are doing everything possible as far as precautionary and taking safety measures and wearing the appropriate equipment, then we should, that should be our universal precautions. So, it's protecting you from infection, from catching that, and then you have to treat all blood and other potentially infectious materials as if they were infectious. You can't make any judgments or exceptions for anybody, and you know, blood-borne diseases can be deadly coming across those. It could be patients that don't tell us the truth and or forgot to write what they had on the paper. You know, they were just diagnosed with it, and they didn't even think about writing it down, or they could be lying. I mean, I want to take them for their word, but some of them don't want us to know when, because they don't want to be judged. So, standard precautions are not enforced by OSHA, but you can use that instead of the universal precautions, and that, I mean, just doing everything that you can possible. It doesn't even have to be universal, standard, whatever. Just using everything that is in your capability of using to protect yourself is essentially what you need to do, and that's what OSHA wants you to do. So, when to hand wash? Use the alcohol-based hand sanitizer and also washing with hands. This could be immediately before touching a patient, before performing an aseptic task, handling invasive medical devices, before moving from a work on a soiled body site to a clean body site, after touching a patient or the patient's immediate environment. You know, that could be airborne. After contact with blood or body fluids or contaminated surfaces, doesn't have to be visible to us immediately after glove removal, and then wash with soap and water when hands are visibly scald, and after caring for a person that's known or suspected infectious disease or after known or suspected exposure to spores, but making sure washing with soap and, you know, the soap and water is before and after, you know, using gloves. Sometimes people have allergic reactions to the powder in the gloves or whatever, so you want to be sure that you wash those hands and keep those hands clean. So, how to hand wash? Soap and water. Wet your hands first with the water, apply the amount of product, rub your hands together vigorously for at least 20 seconds, covering all surfaces of the hands and fingers, underneath the fingernails or in between the fingers, backs of the hands, everything. Rinse your hands with the water and use a disposable towel to dry. Use the towel to turn off the faucet so you're not touching anything, and also avoid using hot water to prevent the drying of skin. And then, with alcohol-based hand sanitizer, put the product on the hands enough to cover all surfaces and the hands feel dry. You're going to just swish it around, make sure, and it needs to take at least 20 to 30 seconds. Same amount of time as the soap and water. So, the use of safety devices. In 2000, President Bill Clinton decided that we needed some sort of standard and worked with OSHA in getting the Needle Stick Safety and Prevention Act. What that did is created engineering controls regulated by OSHA to reduce and eliminate sharps injuries, hoping that those engineering and work practice controls that that we put in place should eliminate, but at least minimize employee exposure. So, a lot of that is checking your safety devices, seeing if you can, you know, substitute them, and making sure that all that gets taken care of every year, making sure that you're trying to find the safest needle as possible or the safest scalpel. And then, only needles that draw at medications are actually exempt from having to substitute. Sharps disposal. You want approved containers are the ones that we usually get from our medical waste companies, but they have to be, the whole reason in these, are they have to be puncture resistant, so nothing's coming through them, leak proof on the bottom and sides, there's no holes anywhere, so that if there was fluid coming off of whatever we put in there, we don't get it on us, and then color-coded or labeled to maintain an upright position, so, because there is an opening and we don't want it falling over and things to fall out, closable, be able to seal it for transport, and do not overfill. That's one big, large thing that I find in a lot of offices, especially large, busy offices. Make sure that if somebody puts a sharp in that box and knows that it's overfilled, they are responsible for replacing it immediately. It needs to be done, because those can lead to large fines. Reusable sharps and instruments must be transported in a container that meets the same criteria, which means that it has to be leak proof, color-coded, leak proof on the bottom and sides, maintained in an upright position, also closable and sealed for transport. So, what you're going to do is you're going to use some sort of box or some sort of container that you can contain this stuff in, that it would not leak on you, that it would not come through the material and stick you in any way, and make sure that you do that and contain it in the room where it was generated. You want to avoid scrubbing, so using an ultrasonic cleaner or enzymatic soap will help with that. Sometimes we absolutely have to scrub. Sometimes our instruments do get coated in things that stick on there that we have to get off. So, if you do have to scrub, you have to wear your gown gloves and face protection, and you want to submerge that into water, okay? Scrub with a brush and the instrument is submerged in the water. You don't want it under running water because that's going to splatter on you. Anything that's going to, I guess, make something aerosol, you don't want that because you don't want it in your eye or mouth or whatever. So, pre-soaking does not sterilize. Work practices. No eating, drinking, or applying contacts or cosmetics in contaminated areas. No storing of food or beverages in contaminated areas. Recapping needles only when medically required. Using the one-handed technique or mechanical device. Also, hand-washing. No hand-to-hand passing of used instruments if another method is feasible. They're just wanting you here, they're just wanting you to make sure that you're doing the safest thing possible. You don't want food or drinks or anything that could possibly get contaminated in those areas. Okay, and so making sure if you are working in an area and bringing up aerosols or you're working and could get blood droplets somewhere, you don't want your food or drink or anything personal in that area. So, making sure that that's not in those areas. Personal protective equipment or PPE. Gloves, gown, face protection, shields, goggles, whatever you need to make sure that you're protected. These are provided maintained and replaced by the employer. And the proper use is just making sure that you put them on correctly, you know when to use them, it's appropriate to the task, and it fits the person. You need to turn it wrong side out when removing so that any area that could have been contaminated is not touching you when you remove it. And then remove and discard and contain where you used it. So, do not walk out of a room fully covered with your glove, gown, face protection, everything that you just worked on a patient with. Get rid of that before you walk to another room. Unless you are going from one dirty room to another in that case, but you're walking through a lot of times the hallway and so you're going to contaminate that area or could run into somebody. And then make sure that you clean hands again. So, the hepatitis B vaccination, it is provided for us through our employer. OSHA makes sure that it is provided for us. And you get, you can get two series of shots provided by the employer. So, if the first series of shots didn't work, you can get a second series. Once you get those two series of shots, then it is up to the employee to go on with it, if they want to continue. The employee can decline the initial request and ask later or request it later. A medical evaluation is needed before the series and the vaccination series and medical evaluation, they will remain confidential. They need to be put into your medical personnel file. Not the health record from the doctor that you're seeing there at the place. Now, shot series, three shots over six months and then a titer, one to two months after the last shot and then you're going to repeat the series if needed for positive. If you need to go five times and you hope to be positive. The third series is paid for by the employee. Laundry. Employees may not take contaminated items or personal protective equipment home. It's recommended that the facility on site would do laundry or you have a washer and dryer. OSHA regulations prohibit home laundering of items, so they don't want you, if something is contaminated, to carry it out or its personal protective equipment out of there and wash it at home. Now, most of our cover-ups and stuff don't get that dirty. I mean, unless you're really, like, for example, if you were working with a patient in the emergency room and they bled all over you. Okay, that's a whole different thing. If you get a splatter of body fluid on you, your jacket usually just kind of absorbs that and you're not going to get that all over you, unless they got a lot on you and it's dripping off of you. That's when they say do not take that home. Okay? OSHA regulations, okay, so home laundering, don't take it home. If no on-site facility, a linen service must be used. With biohazardous waste, we want to discard these items into biohazardous waste containers or those red bags. You want your gloves, if visibly contaminated. Now, your gloves are not absorbent. They are rubber or latex or natural or any of those, and so they're not made to be absorbent, and so you're going to notice the contamination on those quicker, and also that contamination could come off of it easier. So, those get thrown away much easier than materials like gauze and bandages if they don't, if they're not saturated. That's why it's saying saturated or caked. Gloves don't have to be saturated or caked because you definitely put them in the biohazard container if that were the case. Liquid or semi-liquid blood or other potentially infectious materials. Then, you want to seal the container prior to transport. Always wear gloves, gown, and face protection when handling biohazard waste, and then your practice should contract with a licensed waste hauler for removal and destruction of the bio-waste. So, if you have any questions about your biohazardous waste habits and what you do with your stuff, you can discuss that with your biohazardous waste company. With housekeeping, you want to disinfect the work surfaces or remove protective coverings any time that they've become contaminated and at the end of each shift. You want to be sure to wear your personal protective equipment and remove any and all debris and add the EPA registered disinfectant and leave on the surface according to the time on the container. You'll wipe that again after removing the debris and after putting on the EPA registered disinfectant and then discard all those materials into red bags and also clean your hands afterwards, removing your gloves or whatever you have your protective equipment on. Periodically inspect waste containers and clean as needed because a lot of times the red bag will come loose or your regular trash bag will come loose and things get dumped in there. Besides that, so you need to check and make sure. I mean, even if you were to accidentally put something that was sharp somewhere and you're reaching down to pick it up, pick the bag up maybe and then you reach down and you see something in there, you know, you could potentially injure yourself. So, you want to make sure to get that cleaned out. Biohazardous spill kit cleanup. You need to know where your biohazardous spill kit is, but cleaning up the spill, you want to be sure to wear personal protective equipment. You want to place the absorbent, which is going to be like a kitty litter kind of stuff, and you're going to put it on there for about five to ten minutes. Let it absorb it and then you're going to scoop it and place it into the red bag. If there are any sharps associated, if you broke glass, if you dropped a needle into the middle of that yuck, whatever, you're going to want to put it into the sharps container instead. Then you want to clean the area with soap and water and spray it with a disinfectant. Remove and discard and contain any kind of personal protective equipment along with disposing of all personal protective equipment and towels into the red bag. And cleaning your hands, making sure that you always clean your hands anytime after you spill something, clean it up. Making sure that you don't carry on something with you. So, biohazardous labeling. You want to label anything that is thought to be contaminated or something infectious as biohazardous with the biohazard symbol. This will include the ultrasonic machine, enzymatic soaks, anything that you put dirty instruments in. That includes your autoclave. Sometimes, I mean, we all know that, but we need to let people know that may work on it or anything like that and they come in there that those things could be contaminated and having that sticker on there just gives them a warning. Exposure response. If you were to have an exposure, a needle stick injury, a splash or a splatter into the face or anything, you want to clean the exposed area. You want to splash the face with lots of water if it's in your face or scrub any other areas with the soap and water. Then, there is no need to squeeze or puncture the wound to use a disinfectant or use a disinfectant on there. I have known people to actually like put bleach on the area and they whipped, scrubbed it. Then, they even put bleach on the area. There's no use in doing that. I'm just making sure that you clean the area very well and there's no need in like kind of pushing it so that you think, oh, it's going to get that blood out of there. It's going to already be into your skin and into your bloodstream. So, report the exposure to the employer, supervisor, or safety coordinator. Then, document the incident. Determine your course of action. You can actually, if you had a needle stick injury or something like that and you decide that you don't want to have your blood tested, you can decline that and just have your blood collected and preserved and tested later if you prefer that. Post-exposure evaluation follow-up. It should be offered immediately, free of charge, and remain confidential. The exposed employee, also the source individual test, they're all confidential. The person that was exposed to the source individual, they can actually have access to those records of the testing on the source individual, but you all get tested on the same things. They have the right to decline it also, but you need to ask the source individual if they'll get tested, if that was their needle, that you had exposed it to them first and then had a needle stick with it. Source individual and employee get tested for the same things. That's hepatitis B, C, and HIV, and then the evaluation over any kind of reported illnesses need to be kept track of. Counseling must be offered. That is something that they will ask you if OSHA ever reveals any of that information and there's been an exposure, they're going to ask were you offered any kind of counseling afterwards. Now, electricity, electrical safety. When I do a review of an office, I will look at the floors, the ceilings, the walls to make sure that there's nothing unsafe falling in, falling off the walls, anything like that, but I also make sure that the the wall outlets, there's no, the wall outlets are covered. There's a ground fault circuit interrupters where there's water. Cords are placed where they need to be placed. They're not in areas where people could trip over them or they could roll over them with their chair 20 times and cause possible injury. And then lockout tagout is actually to prevent harm from a major source of energy. So an example of that, we don't normally use that in a lot of our offices, but it is known to be used. So any big pieces of machinery or things, anything that you don't want somebody messing with because it's broke, you put a sign on it. You know, so a copier or the scanning machine or the x-ray machine, and you say, do not use, you know, you need to repair or whatever. Those are examples of what's called a tagout. Now, lockout is if they were to put a lock on it so that you couldn't use it, okay? This can include x-rays and MRIs. Radiation. X-ray chemicals, if used, must be labeled. Radiation symbol must be on the entrance of the department. Eyewash station must be available if chemicals are used. So if you're still using a processor that has the fixer and developer in it, then you have to use an eyewash station or have that available close by. Lead-lined personal protective equipment. This can include aprons, gloves, thyroid shields. Some for us, there are available, but mainly these are for the patients, but you want them hanging or laid flat, but never folded up. Those can get breaks in the lead and cause a lot of damage and also exposure to the patient. Shield may be required depending on use. And then badge should be worn at least initially for some radiology procedures. Now, it is not required by OSHA that you wear a badge. However, they do like to see that you're doing the safest thing possible. So if that means having a badge worn for those people that are or could be possibly exposed to radiation, then do it, okay? You know, I know a lot of things are a lot of trouble and you gotta buy this extra and you gotta do this, but in the long run, it will save you a lot of money by doing the safest thing possible so that you don't get fees or fines or anything like that from OSHA. Lasers, beam hazards. Some of you may have lasers, some of you may not. The biggest thing is to wear your manufacturer's instructions and recommendations, and they'll tell you what you need to do. Some of them are larger or some of them are smaller depending on the body part that you're working on. These can cause, the beams can cause fire, eye damage and burns. Non-beam can cause smoke plume infections and chemicals and the exposure to those chemicals. And then those controls are to eliminate or cover reflective surfaces, eliminate flammables or cover with a damp towel. Wear goggles. They usually come with goggles or you buy goggles to go with them. Ensure proper functioning of the smoke evacuator. If you have a large enough laser machine that you need to have one of those available and then wear your laser face mask. Emergency action plan. You want to notify all employees of what your action plan would be if there was to be an emergency. Now, emergencies can go, can be broad. They can be weather emergencies, they can be chemical emergencies, they could be active shooter emergencies, they could be, so you're able to have a lot of different emergencies possible. So being, even like a needle stick injury, I call as an action plan or emergency action plan. What are you gonna do when this occurs? What's gonna happen? Workplace violence, what's gonna happen? How are we gonna handle this? And so these are being prepared in these ways. So what would you do if there is an emergency and you have to get out of the building? That's one of them. What would you do if there's an emergency like a tornado and you have to stay in the building? Where are you gonna go? So knowing where these places are, making sure that every employee is trained on them when they come in and that they know these risks, okay? Business staff, this is, you know, if you're getting out of the building and anyone in the reception room, they need to let them know. And then the clinical staff, assist co-workers or anyone in the patient areas, let them know, exit through the nearest unobstructed exit and you're going to meet at the designated place, whether it's outside or inside, wherever you're going, meet, gather everybody up and make sure that everybody's gotten in there okay. If we have to extinguish a fire, we don't necessarily want you to grab a fire extinguisher if there's a large fire, okay? Not, even if each of you grabbed and you had five of them in there and it was a large fire, it's not gonna happen. You're gonna get burnt, somebody's gonna get hurt, don't worry about it. This is if there is a very small fire that needs to be put out and you can use a fire extinguisher because these don't last very long once you initiate or initiate them and start using them, there's not a lot of fluid in there. So it runs out very quickly. Learning or using one of these at some point, you would see that they don't contain a lot of stuff in there. So you're going to remove the bracket or remove it from the bracket, the wall, the cabinet, whatever it's holding, wherever it's at, and there's a safety pin and you're gonna pull that safety pin. That is holding that handle so somebody doesn't depress it and doesn't use it unless it's needed. Then you're going to depress that handle and you're going to let that spray out the nozzle or the hose, you could have a hose on it, and that pressure gauge needs to read in the middle, straight up and down, hopefully, because that means that it's just kind of mid area, but it needs to be in the green area, okay? So the yellow arrow needs to be within the green area, otherwise it's undercharged or overcharged. So aim the nozzle at the base of the fire, standing about eight to 10 feet back and using a sweeping motion and then approach the fire. Visually examine the extinguisher monthly and document, and then the fire extinguisher will get serviced professionally every year. Hazardous communications standard, this has to do with the chemicals, manufacturers must. The big thing about this is they changed it in 2012 and they wanted to make sure that the manufacturers did what they were supposed to and that we do what we're supposed to. So all the information should be provided for us, the SDSs, the hazards, the information on the containers. Then we have to make a chemical list, updated annually, know what the written program is, what you should do in case of emergencies, you know, how you handle a spill, those kinds of things, be knowledgeable on that written program. And then also label the chemicals, anything that you are taking out of one container and putting it into another one is a secondary container. And you have to label it if it's not already got a pre-label on it. Then you want to make sure that you have your SDSs together, they used to be MSDSs, and then be sure that you have training on all this information. Make sure that even non-hazardous chemicals are labeled within your office. You need to make sure that any chemical in a bottle that does not have a label has a label on it, okay? And even if it's non-hazardous, because they want to know what that chemical is. They don't know if it's hazardous unless you put a chemical on it, or non-hazardous. Side effects of chemical exposure, short, quick effects, happen to do with sneezing, coughing, runny eyes, nose itching, irritation, rash, headaches, nausea, vomiting, diarrhea, and even death. But chronic can be organ damage, cancer, fertility problems, genetic problems, birth defects, and also death. So acute is very, I guess, onset, fast onset, and chronic is more over time. So to realize that, then you can see the difference in the damage it does. These are the pictograms, and I'm gonna tell you ways to remember these pictograms so that you know when you see one, you can recognize it, and you know what it is. So this one's the other one with a person on their chest. These are more of chronic side effects, okay? Cancer, mutations, reproductive toxicity, organ toxicity. So it's toxic to the body, okay? So it's a health hazard. They're gonna show you this pictogram, nothing else on it, no words, no nothing, and they're gonna say, what is this? You can't say it's a person with a star on their chest, okay? You're gonna need to say that it is, and you could be questioned this if OSHA comes into your office, and that's one of the things that they can ask you, and they will interview all employees if they can get to every one of you. Gas cylinder, gases under pressure. This one's not so hard to guess, but remember, it is not a rolling pin or a wine bottle, okay? Don't remember this as it's a gas cylinder. It's gases under pressure. Exclamation mark. It is more of an acute reaction. So it's going to be more something that has occurred quickly or a quicker onset of symptoms. This has to do with skin sensitizer, acute toxicity, so when it says acute, it means that it happened immediately, toxic. Narcotic effects, irritation. If you just remember that this symbol means that it could cause irritation for eyes or skin or any sensitive areas, then you'll know. Also, exploding bomb. They're probably not gonna ask you this one. It's kind of like there's one for a flame, and so you know that it's flammable. Exploding bomb knows that it could be explosive. So you can see that it's blowing apart, you know? So they're gonna say, what is this a symbol of? Well, it's an exploding bomb, okay? Corrosion. This is a little bit more difficult to realize what this is, but this is skin corrosion, burns, eye damage, corrosive to metals. It is dripping a chemical out on skin or out on a metal surface, and so it can do damage to both. So remembering that, if you were to ever be questioned on that. This is the only one that actually kind of shows an action of something going on. All the others really just show a pictogram, but they don't show something happening, and you can see those little squiggly lines. It's like an action it's doing to that surface. You got a flame, flammables, self-heating, emits flammable gas, flammable. It's mainly what you need to know about that one. Flame over a circle. The O in the middle is what you're gonna try to remember, or oxidizer. Environment. It's the only one with the environment on it, okay? So it's got a tree, it's got, it's a dead tree, dead fish, dead water, or black water. So it means that it's environmentally unsafe, okay? Or aquatic toxicity. Skull and crossbones can mean acute toxicity or fatal or toxic. They could even, you know, I mean, I don't know, but if you say, well, it's poisonous because that's a skull and crossbones, it could mean death, you're probably gonna get it right, okay? There's two signal words. There's danger for more severe and warning for less severe. You're gonna see these on your SDS sheets. You're also gonna see them on the labels. Same thing for those pictograms. They'll be on the labels and also on the SDSs. So your SDSs are hazard communication safety data sheets. They used to be called material safety data sheets, but now they're called safety data sheets. So if you see MSDS, it's gonna be the same thing. Safety data sheets is what the new name is. And that has been a correction since 2012. So if you don't have that correction, they may think that you have not updated your information. There are different sections. There are 16 sections. That's one thing that you should remember. There's 16 sections to a safety data sheet. The other thing is that you need to remember that it will tell you everything about a chemical that you really never wanted to know, but it's gonna tell you how to use the chemical, how to store the chemical. Can you mix it with something else? What if you spill it? What if you store it somewhere that's gonna explode? What do we do? How do we take care of it? You know, did it cause a fire? How do I clean it up? It's gonna let you know all those. The firefighting measures, accidental release measures, handling and storage, like I said, safe handling, and incompatibilities, so things that you can't store them with. Also, stability, reactivity. The big things that we're not gonna have to worry about are section 12, 13, 14, 15, those that's got the stars by them, and then section 16 is gonna have some information that we may want to know as far as the data preparation and the last revision to the chemical. Chemical hazard controls. Engineering controls, like good ventilation or properly functioning hoods, things that you can put into place to assist you in the fumes, and then also personal protective equipment, gloves, gown, face protection. Substitutions, things that you can do to possibly get rid of the chemicals that might be causing a problem. And anything that you can do to assist a problem or something that could be causing harm to other people, if you substitute it, it's gonna look good for you as far as OSHA's concerned. And then good work practices, no eating, drinking, or applying contacts or cosmetics where chemicals are used, and cleaning work surfaces. Also, hand washing, making sure that you hand wash. Chemical spill cleanup. You want to be sure the very first thing that you're gonna do is go get the SDS sheet and get your spill kit. You're gonna come and then you're going to see what PPE you have to wear or put on. You're gonna place the absorbent in it and leave it on as long as it tells you to, but it's usually about five to 10 minutes. You're gonna scoop that up and you're gonna place it where the spill should be placed, depending on the SDS will tell you. Mainly, it goes into the regular trash, but if it needs to be put in a special place, it will tell you there. And then clean the area with soap and water and remove and discard or contain the personal protective equipment along with disposing of all personal protective equipment or PPE and the towels into where the spill was placed. And then be sure that you clean your hands. Eye wash stations. You definitely need those eye wash stations if you have any kind of chemicals that could burn or do damage to the eyes. So you want to get to an eye wash station immediately if you've gotten something in your eyes. This could be even a blood splash or it could be a chemical. Activate the eye wash station and hold both eyes open and flush for 15 minutes. It's better to have one that you can activate and not the bottles for the fact that your bottle is going to run out of water at some point and it's very hard to hold your eyes open while you're using a bottle. If it just got in one eye, that's perfect because you can use both bottles and you can just squirt and then use the other bottle. But if you're using it in both eyes to try to wash both eyes out, it's very hard for you to keep your eyes open without holding them open yourself and you have no hands. So make sure you check once a week, flush the eye wash station, allowing the water to flow through for at least three minutes but preferably for 15 minutes. And then test the flow of the water through the eye wash each week so that the eye wash cap pops off. And then record those results in initial. Ergonomics, back injuries, good back. It's using good body mechanics while you're working. Using common sense in protecting your back, knees, wherever you're working, in being safe when lifting, using the computer, in your daily tasks, making sure that you're in a position that doesn't harm you, okay? So carpal tunnel syndrome is a lot of times caused by a lot of keyboarding, improper keyboarding, positioning of your computers, if you're not sitting at the computer right. Also, when we talk about ergonomics, it's one of those things under the general duty clause, just like this is, the workplace violence, is that we have staying calm, using neutral words, tone of voice. If somebody approaches you and becomes violent, you want to be sure that you document everything, you go get help if you need it. Also, the big things to not do is to ignore the person or walk away from that person, make promises you can't keep, like, oh, we'll be able to take care of that for you, don't worry about it because you're just trying to calm them down at the moment, but they can get really upset if they know that you liked them. And then exacerbate the situation by being confrontational. So if you're that kind of person that wants to come back at them as they're coming to you, it could cause a lot of trouble. So we want you to stay calm in this situation because there are other people involved that could get hurt if you start acting that way. Airborne diseases. So there are several examples of things that we could come in contact with that happen to do with airborne diseases. We just want to make sure that we're washing our hands when entering or leaving the room, using personal protective equipment, wearing our personal protective equipment as far as an N95 respirator or surgical mask if that's not available, but gloves, gown, goggles, face shields. You may be wearing two masks. Limit the transport movement of the patients because spreading it throughout the office. Use disposable or dedicated patient care equipment if this is not possible, disinfect and clean equipment thoroughly between patients and prioritize cleaning and disinfection of the rooms. Making sure that you're doing everything possible and following the rules or regulations or whatever's been laid before you as some policies and procedures that your office has said, okay, you have to do this, you have to follow it this way. Some examples can do with flu, TB, and of course, COVID-19. So, in December of 2019, we were talking about airborne diseases and, you know, tuberculosis, COVID-19. In 2019, the SARS-CoV-2, or COVID-19, appeared and we're having to deal with that. The COVID-19 virus spreads primarily through the droplets of saliva or discharge from the nose if an infected person coughs or sneezes, very similar to what TB is, because it's an airborne disease. So the symptoms of the active disease can be asymptomatic. Those people that now we're seeing a lot of people going through and having a difficulty. As COVID advances, the symptoms, some symptoms seem to be easing off, others seem to be getting worse. And so there's fever, chills, cough, fatigue, sore throat, and can even have digestive issues through COVID-19. So we are treating it differently now, however, than when it originally started. So, in the COVID-19 plan, it is, you're supposed to have a COVID-19 plan if you have more than 10 employees. I even tell my smaller practices to have a COVID-19 plan. What you would do if there was a breakout of COVID and to, those things that you would do to protect your employees. You need to have those written somewhere and how the practice will handle that. The employer must have a safety coordinator that actually oversees what is going to happen during that time. So, the hazard assessment, looking at, you know, how bad the COVID is, what you're going to plan to do with that, and then developing and implementing a plan that actually works to that assessment once you've looked at that. The assessment will be based on the job tasks, kind of what we do at the beginning of actually creating an OSHA plan or a safety plan. You have to look at what's causing the problem and how you're handling it at the time, and then you're going to base your new practice or policy off of that. So, this plan will be monitored and updated as it needs to be, and especially with COVID, we're changing, it's coming, you know, it's mutating, it's having a lot of difficulty, you know, some people are having worse symptoms, some people are having easier symptoms, so we have to see what's going on within that to decide what kind of plan and how our plan will be created for that. So CDC recommendations is what we need to follow. Now we still have the emergency action plan, we still have what we're going to do as far as COVID exposures and things like that if it gets to the point where we're actually having the pandemic like we did before. However, they have lessened those things that we're supposed to do as far as questioning and wearing the mask all the time. The heavy-duty masks and wearing those, we're not going to have those respirators, so we're not going to have to do that like we were before. However, they recommend that instead of quarantine, if you were exposed, that you're just going to wear the high-quality mask for 10 days and you're going to get tested on day five to see if you actually have COVID. Now, if you've had the vaccination and you've had multiple vaccinations, you're still going to isolate from others when you have COVID. Unfortunately, there's still a chance to pass it on to others, so you want to isolate if you're sick or suspect that you have COVID-19, but you don't have the test results, possibly her having a couple of symptoms or you might think that some of those symptoms might be related to a time that you were exposed, and if your results are positive then you're going to follow those CDC full isolation recommendations. If you're negative, you can actually end your isolation at that point. So, on the next slide, we're going to go over those recommendations. So, for the other CDC recommendations, they recommend that if you test positive, you need to stay at home at least five days, isolate from others, and during those five days, you're most infectious, so you want to make sure that you wear a high-quality mask if you have to be, absolutely have to be. Now, they want you to isolate, but if you have to be around others, like if you have to go to the doctor, then you're going to wear that high-quality mask. So, after five days, if you don't have a fever for 24 hours and your symptoms are actually improving or you didn't have symptoms at all, you could actually end that violation after day five, but regardless, when you end the isolation, you need to stay away from people during that isolation, especially if you are more likely to get sick from the COVID-19 up to at least day 11. So, after that day 10, you know, re-evaluating how you feel and what symptoms you're having or if you're having any symptoms or anything, always wear a high-quality mask through day 10. Other CDC recommendations, we're recommending that if you have a moderate illness, if you could experience shortness of breath, if you're having difficulty breathing, or even a severe illness where you were hospitalized due to COVID, you're going to have a weakened immune system, so you need to stay away from people and be isolated for those 10 days. So, recommending that if you've had a severe illness or have a weakened immune system, you need to make sure that you consult your doctor before ending that isolation. There is a viral test that may be an option for you, may not. If you are unsure that your symptoms are moderate or severe or you have that weakened immune system, still please talk to your health care provider to make sure that everything's going to be okay, that you're okay to go out, you're okay to be around other people. So, we want to clarify with all those CDC recommendations, even though you may have ended your isolation, if your symptoms are worsening or if you start getting other symptoms, you need to restart your isolation back at day zero. Then, you want to consult with your health care provider on any questions or symptoms when to end that isolation. So, they used to recommend the screening through those patients and through those coming in and all that, unless those patients are actually having like been exposed or have been exposed or not having symptoms, because some of them don't have symptoms ever, but they're not feeling well or they think they may have it. It's no longer recommended that you're doing that screening and asking all those questions and walking all your patients through that. Now, you can ask them because you're still going to ask them some questions. Some people will still ask them, have you been exposed? Have you been around anybody? Because then that gives them an idea that you could have that, but you're no longer actually doing that before they even get into the office. Emphasizing that physical distance on how to protect yourself from others. It's very important that you realize that in your setting. It's going to help if you have improved ventilation, those physical distances. So, you know, a lot of office will have a sick room and a well room so that those that are sick can be in one area and those that are well be in another area. So, that is recommended that you may separate those in your waiting room or you may bring in those that maybe have COVID or been exposed in through another way through your office, just like you did if when COVID-19 was going on. So, you may, it's important to consider that at protecting your employees and also protecting those other patients that you have coming in. So, tuberculosis. It's still part of the COVID information as far as what they, what it does. Okay, so it's droplet nuclei. When an infected individual coughs, it can be latent or active just like the asymptomatic, but if you're having symptoms, then it's a productive cough longer than three weeks, coughing up blood, night sweats, fatigue, weight loss, anorexia, and fever. So, similar, similar. Some of them are the same, but even the flu, you know, it's going to be a airborne problem. So, OSHA requires a tuberculosis program only in settings that perform the high-risk procedures or that have patients suspected or known to have active pulmonary tuberculosis infection. So, if you are treating patients that could have TB, like if they come in there and they say that they're having those symptoms and you find out that they have TB, then, and it's a frequent, you know, I mean if you haven't had one, you've had one person come in there with TB in 10 years, then it's not going to be a large program. It's going to be something simple, something very quick, just kind of laid out, here it is, you know, this is what we're doing if somebody with TB comes in, you know, and for example, these policies, now OSHA has a policy template online that you can go to at OSHA.gov when you need that policy template, but with TB, what you're going to do is you're going to say, if a TB patient comes in, we are going to immediately refer them out for treatment if this is not what you do in your office, and any person that was around them or exposed to them will have testing done, and we will provide anything that they need as far as that's concerned, okay. So, this just kind of a, you know, the way you would put your policies in place, that information, using that information. So, determining whether you need one or not, like I said, if you're, if you don't do any high-risk or you don't have any patients that come in with active pulmonary tuberculosis, then you don't need the complete TB program. That means like the mask and the testing on the mask and and all that and the training and all that, like we had to do with COVID, and therefore you do not have to have an annual employee skin testing unless required to do so by another agency. It's a good idea to do it as employees come in to test them to see if they have TB coming in, but also, you know, it's probably going to be a big thing now that you test people for COVID before they start work. Then, according to the CDC guidelines, every practice should do an annual risk assessment and initial employee skin testing. So, when you say an annual risk assessment is what tasks are these employees going to be doing in your office that could risk them harm? I mean, you know, or could cause them any kind of harm. That's kind of how you have to think when you're talking about OSHA. Okay, this person back here is going to get into more stuff than this person up here, so that is where it lies as far as that's concerned. It's very important that we keep track of these COVID incidences, each employee, and having it. If they have hospitalization, you have to let OSHA know within 24 hours. Actually, I think it's even eight hours, so the shorter the better. All right, making sure that you record it, you record how you treated it, all that information, and then also reporting it as needed. Now, there is partial exemption as far as the 300-300A form. They may ask you to keep that, but the biggest thing is making sure that you write down anything that related to COVID because that's going to be the thing that they're going to pick on recently because it's the biggest thing that's come out. So, making sure that you cover your bases, all bases, when it comes to COVID. Documenting, injury documenting, hospitalization documenting. If someone's out, how are you going to handle it? Making sure that documentation is taken care of. Did somebody get a vaccine? Making sure you have record of that, you know, because I don't know if they'll ask for that or not. They do ask to make sure that you at least offer the hepatitis B vaccine. So, they even see those, so I don't know why they wouldn't ask, you know, hey, did you offer the hepatitis or the COVID vaccine? So, and we also have a declination form that says, no, I don't, I don't want it, so that you can have that in your chart also. Things you have to remember. These are things that they could possibly ask you. So, remember these. I know that you had to listen to this whole training and everything, but these are the most important points because these are things that I can't train you on. You would need to know these from your office itself. So, who's the OSHA person in your office? Where is the OSHA poster, OSHA manual, and SDS kept? Where are the fire extinguishers, eyewash stations, spill kits, and how to use each one of those? What each pictogram represents and what an SDS looks like? What your emergency action plan is? What should be done when there's a needle stick injury? How to handle a workplace violence incident? How to clean up a biohazard or chemical spill? Where your spill kits are located is very important also. Where is your personal protective equipment located? And know what chemicals are used in the office and know their side effects. Thank you so much for attending today's webinar. If you have any questions, please reach out to AAD Compliance website at aad.org backslash compliance or you can reach out by email at practice center no spaces at aad.org. Thank you again and have a great day!

OSHA compliance

health and safety regulations

medical practices

dental practices

bloodborne pathogens

workplace violence

tuberculosis

COVID-19

employee rights

General Duty Clause

HIPAA training