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Regulatory Compliance Manual: Table of Contents and Use Instructions

September 01, 2011 3130

Introduction

This manual, originally developed in 1992 for California Dental Association members, is regularly reviewed and updated as needed. Although every effort is made to ensure the accuracy of this information, the CDA is not responsible for any errors and omissions, or for any agency's interpretations, application and changes of regulations described herein.

This manual is designed to provide practical information in a summarized manner in regard to the subject matter covered. It is provided with the understanding that the association and others that are associated with this publication are not engaged in rendering legal, technical or other professional service. If legal or other expert advice is required, the services of competent professionals should be sought.

It should be noted that this manual alone does not comply with Cal/OSHA's requirements for employee training. Acceptable training methods include trainer/trainee review of written material with question-and­ answer format, classroom presentations, recorded presentations, and internet-based interactive courses.

How To Use This Manual

Successful implementation of this manual in your dental practice is dependent on a basic understanding of the regulations covered in this manual, as well as on the cooperation of each member of the dental team. The completed manual should be reviewed on an annual basis by the dentist-employer and, if possible, by one or two staff persons to ensure that the procedures described in the manual are the same ones followed in the office. The completed manual may be used as a training aid, but the manual alone does not comply with the requirements for employee training. For example, Cal/OSHA's bloodborne pathogens (Exposure Control Plan) training must include a discussion on the epidemiology and symptoms of bloodborne diseases. This manual does not include that discussion. Such information can be provided in journal articles or at lectures.

The CDA Regulatory Compliance Manual is intended to provide you with a detailed overview of regulations applicable to a dental practice, and a "shell" for required written plans. Cal/OSHA requires several written plans, and the Injury and Illness Prevention Plan serves as the "umbrella" plan for the others. The dentist employer or designated employee must complete the written plans, i.e., the blanks need to be filled in and boxes need to be checked. Written plans include blank training documentation forms and checklists. Some training resources are listed. A separate Records section in the manual contains blank sample forms that you can photocopy before completing.

The California Department of Public Health (CDPH) requires a written Medical Waste Plan, a sample of which is included in the manual. The manual also includes two guides - one on radiation safety and regulations and another on regulated waste management.

The best method for implementing the manual, as demonstrated by tests conducted in some dental offices, is to assign a staff member to be responsible for completing each specific written plan. For example, a hygienist or dental assistant is a good choice to help complete the Exposure Control Plan. Administrative staff would be a good choice to complete the Fire and Emergency and General Office Safety plans. A combination or team approach of the staff can be used for the Hazard Communication Plan. Each person assigned to implement a specific plan will train other employees in the requirements of the plan. The training can occur individually or in groups; whichever method the dentist-employer prefers. Training is required to be provided annually, when a new procedure or product material is introduced in the office, and to new staff as soon as possible after hire.

To use this manual, you should:

  • Review the organizational structure of the manual
  • Assign specific staff members to review and implement each plan
  • Have responsible staff members train other staff members on the requirements of each plan.

Table of Contents

Individual manual sections are updated as needed. Rarely is the entire manual updated. To check for updates, compare the printed date on each section of your copy of the manual with the date included in the online summary of the section.

  1. Introduction
    1. How to Use This Manual (you are here)
    2. Frequently Asked Questions
  2. Injury and Illness Prevention Plan
  3. COVID-19 Addendum to the IIPP
  4. Respiratory Protection Program
  5. Exposure Control Plan
  6. Hazard Communication Plan
  7. Ergonomics/Repetitive Motion Injury Prevention Plan
  8. Fire & Emergency Action Plan
  9. General Office Safety Plan
  10. Records – blank forms to copy and complete
    1. Schedule and Method of Implementation
    2. Employee Medical Record Form
    3. Informed Refusal for Hepatitis B Vaccination
    4. Identification, Evaluation and Selection of Engineering and Work Practice Controls
    5. Housekeeping Schedule
    6. Sharps Injury Log
    7. Dental Sharps
    8. Individual Training Documentation
    9. Employee Accident Form
    10. Confirmation of Source Patient's Denial for Testing 
    11. Employee Informed Refusal of Post-Exposure Medical Evaluation
    12. Bloodborne Pathogens Post Exposure Management Protocol
    13. Written Opinion of Health Care Evaluator
    14. Employee Injury Protocol
    15. Instrument Processing Protocol
  11. Medical Waste Management and Disposal Plan
  12. Hazardous Waste Management and Disposal Plan
  13. Radiation Safety in Dental Practice: A Study Guide
  14. Appendices
    1. Bloodborne Pathogens Standard
    2. Access to Employee Exposure and Medical Records
    3. Dental Board of California Infection Control Regulations
    4. Required Postings in a Dental Office