Copyright 2012. Assurance 360. Protecting Your Profits. Eliminating Your Liabilities. All Rights Reserved.
How often is your sterilizer being monitored? Did you know that the Centers for Disease Control recommend spore testing be conducted on a weekly basis? More often than not, we find that spore testing practices do not meet these standards. Every practice must clearly identify the frequency and the means by which sterilizers are being inspected in their Schedule of Housekeeping & Decontamination. Additionally, they must document each inspection in an Inspection Log. If you're not doing this, there may be a tremendous amount of liability in your practice. There are three accepted forms of monitoring:
  • Mechanical
  • Chemical
  • Biological (Spore Testing)

Biological monitoring is the most accepted means of monitoring and must be conducted on a weekly basis. Practices must also conduct spore testing whenever the following conditions are present: 
  • After training new sterilization personnel
  • After changing packaging material or trays
  • After the sterilizer has been repaired
  • After chaning loading and unloading procedures
Remember to document your selected best practices in your Schedule of Housekeeping & Decontamination. Additionally, ensure that employees are documenting each inspection in an Inspection Log. These best practices will support you in ensuring the protection of your employees, your patients, and your practice.

You may have noticed some changes with the hazardous chemicals being delivered by FedEx or UPS recently, The United States department of Labor has adopted the United Nations' Globally Harmonized System for Classification of Hazardous Chemicals.  This changes the way hazardous chemicals are classified, chemical labeling, safety data sheets, and employee training. Dental practices are required to comply with either the current standard, the new standard, or both during the transition. The transition is expected to be finalized in 2016 and employers are required to provide training regarding GHS by December, 31st 2013. Our professionals are prepared to provide your team with the necessary training, as well as, ensure your compliance with GHS. Our app is loaded with resources to support you and your team in eliminating areas of liability regarding OSHA rules and regulations and promote a safe and healthful work environment. IIt is the only resource available that GUARANTEES you compliance. Call today!
A District of Columbia dental practice was recently cited for failing to cmply with OSHA standards. OSHA issued 26 serious violations, accumulating $61,000 in citations for the following concerns:
  • No written Exposure Control Plan
  • No written Hazard Communication Plan
  • Failing to ensure sufficient work practice controls to eliminate or minimize exposure
  • Failing to follow egress rules and regulations
  • Failing to provide HBV vaccinations within 10 days of employment
  • Failing to ensure use of proper Personal Protective Equipment
  • Exposure to electrical hazards
A serious violation is issued when there is probability that death or serious injury may occur. The practice has 15 days to correct the areas of non-compliance. All of the aforementioned concerns could have been easily prevented with the Assurance 360 app. Additionally, we support practices in correcting violations proposed by OSHA and guarantee our products and services services.

Emergency Action Plans

The common approach to emergencies (i.e. fire, tornados, earthquakes, hazardous chemical spills, severe employee injuries, etc.) is essentially to leave all the major decisions to the leader and request direction and support in the resolution. Why? Because these occurenses are typically infrequent and therefore are not given the level of attention they deserve. The truth is that most small business owners do not have a predetermined plan of action and cannot effectively and efficiently direct and support subordinates. The result is astronomical costs associated with damage, injuries, loss in production, increased insurance premiums, the list goes on. It is imperative that business owners be responsible in their efforts to plan ahead and be prepared in the unlikely event of a significant environmental challenge. Being prepared will promote employee safety, reduce injuries and costs, and ensure all team members are equipped with the knowledge to take immediate action. Emergency action plans are required for practices employing 11 or more employees and should be a consideration of all dental practices. To support you in developing and implementing an Emergency Action Plan in your practice, we have listed the requirements below.

Methods of reporting emergencies
Procedures for accounting for all personnel during and/ or following an emergency
Procedures for operational shutdown
Protocols of communication (Chain of Command)
Evacuation procedures and paths of critical egress
First Aid Assignments
Procedures for personnel who facilitate the resolution

For further support and clarification of these items, please contact us to schedule your initial comprehensive assessment.

Although the Job Safety & Health Posters are an important component of OSHA compliance, this resource in and of itself does not ensure compliance. I am finding more and more practices that have taken the initiative to aquire and display the poster and are operating from the assumption that they have satisfied much of what is required by OSHA. If only this were true. It is important to understand that the poster itself does not satisfy your requirements, rather, the content and resources it contains does. The poster typically includes the OSHA's Standard for Safety & Health, The OSH Act, and OSHA Forms 300, 300A, and 301, which may or may not be required, depending on the number of people you employ.  Additionally, I am finding that the posters and other required signage required by the Department of Labor are not being posted prominantly. This is a critical factor in that the sole purpose of these documents is not to simply be posted, but to educate and inform employees. This information needs to be discussed and reviewed peridocially, as well as made a priority in your practice.
The Obama Administration is working with OSHA to increase the number of inspections and the amount per fine for violations. These new enforcement initiatives for OSHA rules and regulations is an effort to recooperate from the current financial crisis. Is this the right move? Well it depends. Of the 2,400 state and federal inspectors and more than 8,000,000 small businesses that are regulated by OSHA, one might say they can't possibly cover them all. The result is insufficient accountability on behalf of small business owners to be OSHA compliant and therefore, less than adequate safety and health measures in their respective businesses. Small business owners will inevitably face additional costs, and these costs can be reduced or even eliminated with proper legal and environmental compliance support. Another might say that due to the increased number of inspections and larger fines, the demand for these services will increase substantially. Increased demand means employing additional resources, job creation, improved safety and health protocols in the workplace, and reduced costs for injury and illness which is estimated around $145 to $290 billion per year.  Small business owners will no longer be able to neglect proper safety and health measures. Fortunately, preventative resources are available to prevent the substantial costs associated with fines, in addition to the direct and indirect costs associated with injury and illness. So, is it the right move.....job creation, economic growth, increased accountability, a more safe and healthy workforce, and a means for financial recovery.....I think we finally got one right. Would you rather pay higher taxes and  fines for non-compliance or invest in making your practice a better place to work?  We can view this as a penatly for the mediocre financial controls of our government or as an opportunity to improve our businesses. We can pay for the government's mistakes or invest in our own economic prosperity. Which road are you taking?
After conducting the first round of beta tests, it is clear we are on the right track. There is absolutely a need for attention to OSHA standards in the dental community. Unfortunately, this is an area of liability that has brought about little concern in the past and is now becoming more and more a hot item amongst the dental community as legislators seek to raise fines for non-compliance. There is on average, 5 defects at any given point in time in a dental practice. Of the beta tests completed thus far in our venture, this number doesn't even compare. We have found tremendous levels of liability that will bring substantial fines if not corrected. We are supporting these practices in correcting their existing deficiencies and implementing workable solutions to prevent them in the future. My question to you is.....if an OSHA inspector were to walk into your practice today.....are you compliant?


    Jon Harris has been coaching and consulting small businesses for more than a decade. His expertise in legal and environmental compliance comes from years of experience assessing liability, developing and implementing action plans to eliminate those liabilities, and pioneering best practices to prevent reoccurrences. He is bringing his corporate experience to small business to foster a new approach to managing liability.
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Copyright 2012. Assurance 360. Protecting Your Profits. Eliminating Your Liabilities. All Rights Reserved.