2018 CAL/OSHA TRAINING FOR ACTION!!

1. 2018CAL/OSHA TRAINING FOR ACTION!! Presented by SUPERIOR OFFICE SAFETY Diane Arns

2. CURRENT CE REQUIREMENTS CA DENTAL PROFESSIONALS • Dental Board of California • Biennial Infection Control Title 16, Sec. 1005 • Biennial California Dental Practice Act • Title 16, Sec. 1016-1017 • Biennial CPR - BLS • Basic Life Support from • American Heart Assoc. or American Red Cross • Cal/OSHA • Annual Bloodborne Pathogen Training, Title 8, Sec 5193 • Initial, Ongoing Hazard Communication Training Title 8, Sec 5194 • Annual Injury Illness Prevention Plan Training Title 8, Sec 3203 & SB198 • Annual Ergonomics Training Title 8, Sec 5110 (Only applies to office personnel after more than one identical injuries from the identical work activity)

3. FEDERAL OSHA OSHA first created in 1970 Dept. of Labor – Asst. Sec of Labor for OS&H Code of Federal Regulations CFR 1910,Title 29 Updated July 1 of each year

4. EMPLOYER EMPLOYEE OSHA STANDARD DUTY CLAUSE • Each Employer Shall (must) Furnish to Each Employee a Place of Employment Which is Free from Recognized Hazards that are Causing or Likely to Cause Death or Serious Physical Harm • Each Employee Shall (must) Comply with Occupational Safety and Health Standards

5. Employees feel more valued!

6. CAL/OSHA Cal-OSHA is the State Branch of Federal OSHA. Cal-OSHA is Responsible for Enforcing California Laws and Regulations Pertaining to Workplace Health and Safety and for Providing Assistance to Employers and Employees

7. JOB-SITE HAZARD ASSESSMENTS Cal/OSHA Requires “Periodic” Job Hazard Assessments to Identify and Correct Hazards in Our Workplace.

8. TITLE 8 REGULATIONS • Title 8, Sec 3203 Injury and Illness Prevention Plan • Title 8, Sec 5193 Bloodborne Pathogens • Title 8, Sec 5194 Hazard Communication • Title 8, Sec 3220 Emergency Action Plan • Title 8, Sec 3221 Fire Prevention Plan

9. CAL/OSHA CONSULTATION All Consultative Services by CAL/OSHA are Provided Free of Charge in California 1-800-963-9424 Answers Employee and Employer Questions Regarding Interpretation of the Law, through Telephone Support, Publications and Educational Outreach.

10. CAL/OSHA ENFORCEMENT • Cal/OSHA has Jurisdiction over Every Place of Employment in California to Enforce Cal/OSHA Regulations. • Cal/OSHA dispatches Inspectors from District Offices in Response to: • A Complaint about an Occupational Safety and Health hazard, • A Report of an Industrial Accident, • Periodic inspections

11. AUTHORITY FOR INSPECTIONS To Enforce Standards, OSHA is Authorized to Conduct Workplace Inspections. To Enter Without Delay and at Reasonable Times, any Facility Where Work is Performed by an Employee or Employer. Inspect and Investigate During Regular Working Hours.

12. INSPECTION PROCESS Confidential Employee Interviews Records Review Closing Conference Inspector reports finding to Cal/OSHA Area Director who Determines Citations/Penalties Employer Must Post Copy of Each Citation at or near a Place of Violation for 3 days or Until Violation is Abated, Whichever is Longer.

13. BEST PRACTICES TO OFFSET OSHA CITATIONS • Update, Maintain and Train all staff on Written Programs in IIPP. • Report Injuries Promptly and Correctly • Post Required Regulations • Provide Employee Training - Initially, Annually or Whenever Changes Occur • Maintain Records • Engage Employees for Compliance in all Areas of Practice!!

14. INJURY AND ILLNESS PREVENTION PLAN STANDARD – Title 8, Sec 3203 7/1/1991, “Every Employer Shall, at a Minimum, Establish, Implement and Maintain an Effective Injury and Illness Prevention Plan”. Training on IIPP – Initially and Annually No Federal Standard comparable!!! Lack of IIPP most cited violation in General Industry

15. INJURY AND ILLNESS PREVENTION PLAN - IIPP • 1. Exposure Control Plan • 2. Hazard Com Plan • 3. Ergonomics Plan • 4. General Office Safety Plan • 5. Office Fire and Emergency Plan • 6. Medical Waste Plan • 7. Radiation Safety • 8. Appendices

16. CDA’S Regulatory Compliance Manual • INJURY AND ILLNESS PREVENTION PLAN • CDA Members • http://www.cda.org/member-resources/practice-support • Download, Personalize and Tailor to Your Practice • OR • Purchase CDA Regulatory Compliance Manual Binder • ~ Top Tab - Members Benefits • ~ Right Tab - Regulatory Compliance • ~ Right Tab - Regulatory Compliance Manual

17. REQUIRED BY BLOODBORNE PATHOGEN STANDARD • Exposure Determination for All Staff • Methods of Compliance for Staff • Hepatitis B Vaccine • Post-Exposure Evaluation and Follow-up • Engineering and Work Practice Controls • Storage and disposal of “Medical Waste” Written Exposure Control Plan

18. EXPOSURES TOBLOOD AND OPIM OCCUPATIONAL EXPOSURE – Reasonably anticipated skin, eye, mucous membrane, non-intact skin, or parenteral contact with blood or OPIM that my result from the performance of an employee’s duties. OPIM – OTHER POTENTIALLY INFECTIOUS MATERIALS!! Semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pericardial fluid, peritoneal fluid, amniotic fluid, SALIVA IN DENTAL PROCEDURES. Any body fluid that is visibly contaminated with blood, such as saliva or vomitus. All body fluids in situations where it is difficult or impossible to differentiate between body fluids such as in emergency response.

19. Modes of Transmission of Bloodborne Pathogens Direct contact with blood or body fluids Indirect contact with a contaminated instrument or surface Contact of mucosa of the eyes, nose, or mouth with droplets or spatter Inhalation of airborne microorganisms

20. Transmission of Bloodborne Pathogens Bloodborne viruses such as hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV) Are transmissible in health care settings Can produce chronic infection Are often carried by persons unaware of their infection

21. UNIVERSAL PRECAUTIONS UNIVERSAL PRECAUTIONS is an approach to infection control according to which all human blood and certain body fluids are treated as if known to be infectious for HIV, HBV, HCV and other Bloodborne pathogens. UNIVERSAL PRECAUTIONS SHALL BE PRACTICED ON ALL PATIENTS! UNIVERSAL PRECAUTIONS ARE DETERMINED BY PROCEDURE, NOT BY PATIENT!

22. Standard Precautions • Apply to all patients • Integrate and expand Universal Precautions to include organisms spread by blood and also • Body fluids, secretions, and excretions except sweat, whether or not they contain blood • Non-intact (broken) skin • Mucous membranes

23. Elements of Standard Precautions Handwashing Use of gloves, masks, eye protection, and fluid-resistant gowns Patient care equipment Environmental surfaces Injury prevention

24. Hepatitis B Vaccine • Hepatitis B Vaccine shall be made available within 10 working days of initial assignments to employees who have occupational exposure. • Provide access to qualified healthcare professionals for administration and follow-up testing • Test for anti-HBs 1 to 2 months after 3rd dose • Unless the employee has previously received the complete vaccination series.

25. WHEN CAN DENTAL TREATMENT RESUME? Infectious TB is unlikely and another diagnosis is made that explains the syndrome Or Patient has 3 consecutive negative AFB sputum smear results, and Patient has received standard antituberculosis treatment (minimum of 2 weeks), and Patient has demonstrated clinical improvement

26. Aerosol Transmissible Diseases/Pathogens Title 8 Sec. 5199 Effective 8/5/09 IIPP includes a written procedure for screening patients for ATD that is current with CDC guidelines for Infection Control in the dental setting and is performed before treatment. Aerosol generating treatment will not be performed if patient has suspected or identified ATD.

27. BBP Standard, Title 8, Sec.5193 Requires a Post-Exposure Protocol to be Established, Maintained, and Tailored to Your Dental Practice.

28. POST-EXPOSURE SET-UP • BEFORE exposures – designate a physician and accredited lab with exposure expertise - Contact your workman’s comp carrier for info!! • Create “Exposure Folder” with: • NAME, ADDRESS, AND MAP TO PHYSICIAN AND LAB • CCR TITLE 8, SEC 5193 – BBP Standard • MEDICAL RECORDS • CONFIDENTIAL MEDICAL EVALUATION FORM • RESULTS OF SOURCE INDIVIDUAL’S BLOOD TESTING

29. POST EXPOSURE TREATMENT OCCUPATIONAL EXPOSURE TO BLOOD OR OPIM REQUIRES TIMELY AND APPROPRIATE POST-EXPOSURE INTERVENTION. 2007 - EMPLOYERS SHOULD MAKE PREARRANGEMENTS TO ENSURE THAT WITHIN 1-2 HOURS OF EXPOSURE THE EMPLOYEE RECEIVES THE FOLLOWING: 1. CONFIDENTIAL MEDICAL EVALUATIONS WITH QUALIFIED PHYSICIAN. 2. LAB TESTS CONDUCTED BY ACCREDITED LABORATORIES 3. TREATMENT AND POST-EXPOSURE PEP DRUGS WHEN APPROPRIATE

30. EXPOSURE INCIDENTS All exposure incidents shall be reported, investigated and documented. For exposures where blood or OPIM contact has occurred, CAL/OSHA requires documentation on 300 log.

31. Recorded on log within 14 days Keep log for 5 years

32. CAL/OSHA PPE Personal protective equipment will be considered “appropriate” only if it does not permit blood or OPIM to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

33. TYPES OF PPE Gloves – Medical Exam, Sterile Surgical, Heavy Duty chemical resistant Gloves, Overgloves Body Protection - Fluid Resistant Gowns Or Lab Coats – Long Sleeved, Closed At The Neck, Below The Knee Face Shields, Safety Goggles, Personal Eye Wear with side shields Masks (also need to be “appropriate”)

34. PERSONAL PROTECTIVE EQUIPMENT PPE Is Determined By Procedure And The Degree Of Exposure Anticipated Written Work Practices Should Specify What PPE Is To Be Worn For Procedures Appropriate PPE Is Provided To Employees At No Cost And Should Be Available In Necessary Sizes Employer Is Responsible To Provide, Maintain, Replace, Launder PPE Wearing Appropriate PPE Should Be A Condition Of Employment All PPE is to be removed before leaving the work area

35. PERSONAL PROTECTIVE WEARIS YOUR PPE“APPROPRIATE”BY FEDERAL AND Cal/OSHA STANDARDS??

36. MEDICAL WASTEManagement Program • Contaminated Sharps • Items that drip or flake blood when compressed • Human surgery tissues • Pharmaceutical waste • Teeth - when deemed infectious-without restorations • Medical waste does not contain hazardous waste

37. HANDLING OF SHARPS Immediately Or As Soon As Possible After Use, Contaminated Sharps Shall Be Placed In Sharps Container At All Times During The Use Of Sharps, Sharps Containers Shall Be Easily Accessible To Personnel And Located As Close As Is Feasible To The Immediate Area Where Sharps Are Used Or Can Be Reasonably Anticipated To Be Found Sharps Containers Must Be Maintained Upright And Replaced As Necessary To Avoid Overfilling All Sharps Containers Must Be – Rigid, Puncture Resistant, Leak-proof, Portable, Closeable, Sealable, And Labeled With The Biohazard Symbol

38. MEDICAL WASTE STORAGE • Biohazard Waste • 7 days ( >20 lbs. monthly • 30 days (<20 lbs. monthly, kept above 0*) • 90 days (<20 lbs. monthly, kept below 0*) • Pharmaceutical Waste - Leak proof container labeled with “Incineration Only” • 90 days (> 10 lbs. yr.) • 1 year (< 10 lbs. yr.)

39. HAZARD COMMUNICATIONSTANDARD Federal OSHA – CFR 29 CAL-OSHA – Title 8, Section 5194 All employees exposed or potentially exposed to hazardous materials must receive initial and on-going refresher training. 1994 OSHA “Right to Know” the Hazards 2013 Globally Harmonized System of Classification and Labeling of Chemicals (GHS) “Right to Understand”

40. HAZARD COMMUNICATIONSTANDARD Develop and Maintain a Written Hazard Communication Plan Consolidate a list of hazardous chemicals and materials used in the workplace Properly label all hazardous materials in the workplace Train exposed/potentially exposed employees on workplace chemical hazards and safe chemical handling Effective 12/1/13 – Train all staff on new GHS

41. OCCUPATIONAL EXPOSURE TWO TYPES OF OCCUPATIONAL EXPOSURES ACUTE AND CHRONIC Acute exposuresinvolve immediate and short term exposures to harmful chemicals or materials – examples would be chemical skin burns, fumes from a gluteraldehyde spill, mixing photo fixer and photo developer. Chronic Exposures involve repeated exposures over a long period of time. Exposures may be associated with relatively low level exposures – examples of low levels exposures could be from Formaldehyde, Nitrous Oxide, Mercury, o’Phenol.

42. HAZARDOUSSUBSTANCES Entry Routes: Skin contact (absorption) Inhalation (vapors, particles) Ingestion Injection

43. GHS - GLOBALLY HARMONIZED SYSTEM New standard still requires chemical mfgs. and importers to evaluate, provide hazard info and labels for the chemicals they produce or import. Provides a standardized single set of harmonized criteria for classifying chemicals, according to their health and physical hazards Specifies hazard communication elements for labeling and safety data sheets.

44. PROPOSITION 65 1991 – CCR – Title 8, Section 5194, Subsection 5194(b)6 “Safe Drinking Water and Toxic Enforcement” Prop 65 applies to all businesses employing ten or more (full-time and part time) employees!!! PROPOSITION 65 requires the governor to publish a list of chemicals known to the State of California to cause cancer, birth defects, or reproductive harm. Prop 65 also requires that businesses provide a clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemical.

45. PROPOSITION 65 Proposition 65 only applies to your practice if: 1. You have 10 or more employees. Employees defined: definition of employee is very broad and encompasses part-time and full- time personnel. Also personnel who provide limited services such as janitors, bookkeepers, gardeners, etc. 2. Prop 65 chemicals are used within the practice. 3. Prop 65 has private enforcement to help enforce the law. Private groups and individuals acting in the public’s interest can also initiate cases.

46. PROP 65 OVERVIEW • Employer must provide a “clear and reasonable” warning prior to “knowingly and intentionally” exposing any person to a listed chemical. • WARNING: This facility contains and uses chemicals known to the State of California to cause cancer and/or reproductive toxicity. • Employer must provide training on Prop 65 and chemical risks. As part of routine hazard communication training, employers must make sure that employees are advised of health and physical characteristics of chemicals in use • Employer eliminates knowing discharges or releases of any listed chemical into water or land which could pass into a potential source of drinking water.

47. PROPOSITION 65LIST OF CHEMICALS www.OEHHA.ca.gov/prop65.html

48. HAZARDOUS WASTES In a dental practice, • Used photographic fixer • Used cold sterile solutions • Dental amalgam (contact or scrap), Evacuation System traps and canisters • Formaldehyde • X-ray system cleaners containing chromium

49. Hazardous Waste Storage Generate less than 27 gallons in 90 days, and less than 55 gal. in one year, Hazardous Waste Storage is Up to One Year from Date Storage Began. Generate 27 gallon or more in 90 days, Hazardous waste Storage is no longer than 90 days. Each waste should be stored in separate waste containers. Label container with the date the waste storage began

50. Hazardous Chemical Storage Store New Unused Chemicals in Secondary Containment. Store Chemical Waste in Secondary Containment. Secondary containment Prevent Spills and Leaks, and Fire Hazards!!