Last Quarter of the Year To Do List

By Olivia Wann

As we enter the last quarter of the year, there are important considerations to make in reviewing your regulatory compliance program.  Let’s start with OSHA.  Next issue we’ll address HIPAA.

1. Have you completed and documented training?  OSHA requires bloodborne pathogens training every 365 days for those who have potential exposure to blood or other potentially infectious material (OPIM).  OSHA requires you obtain a roster listing the signatures and designations of the attendees in addition to the presenters name/credentials, the date, and detail the required topics. Don’t forget required training on the Hazard Communication Standard plus fire and emergency planning.  Retain training documentation 3 years.  

2. Have you completed your safer medical device evaluation?  OSHA requires we annually review safer medical devices and document this review.  Those who are required to participate are non-managerial employees who are in the trenches, so to speak.  They can provide valuable feedback on the evaluation process and in selection of safer medical devices to implement into your program. Document the sharps and needles in use and the devices implemented. There are several new devices on the market that you may want to investigate, such as the NoPo Guard.  I found this fairly new device at a trade show. 

3. Have you updated your Exposure Control Plan?  OSHA requires you review your plan at least every year and provide documentation detailing your review while making any updates necessary.

4.  Have you updated your SDS collection? Be sure you have the SDS that corresponds with the product in use.  If you shop the deals, this makes it even more challenging to keep your program current. We highly suggest using an electronic program.  We provide this solution as well as Patterson Dental.

5.  Have you revised your chemical inventory?  While you’re auditing your SDS, be sure to update the chemical inventory. 

6. Have you checked your employee medical records? These confidential records must contain the HBV vaccine verification or declination. Also, the record show contain any exposure incident reports including the attending health care professional’s documentation.

7. Have you audited your quality control records?  Review the tasks logs to ensure timely completion including the weekly biological monitoring of the sterilizers, quarterly water monitoring, monthly fire extinguisher checks, weekly eyewash station checks, amalgam separator filter changes, etc.

8. Have you reviewed your emergency action plan and updated it with active shooter information? OSHA wants to see active shooter information to include Run, Hide and Fight protocols. 

9. Have you revised your infection control plan?  Update your infection control plan to include your site-specific protocols on surface disinfection, instrument management, quality control procedures including water protocols.  Not capturing your protocols in writing lends itself to errors and a potential infection control breach.

10. Schedule your 2024 training and policy updates. Whether you handle your own program or you outsource it to Modern Practice Solutions, let’s get this important aspect of practice management on the books!