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"How do I keep up with these changes and requirements?" is a common question from laboratory owners. Appointing a safety coordinator is a start, but the owner must realize that he/she is ultimately responsible for following all regulations that apply to their dental laboratory's business model. To stay abreast of OSHA's requirements, business owners can monitor OSHA's website (osha.gov) plus sign up for QuickTakes,1 which sends out RSS feeds with important health and safety information. Since 28 states have state OSHA plans, a dental laboratory in one of those states must also keep abreast of state-specific requirements.2
Other methods that can be used to learn about OSHA requirements include:
• Becoming an OSHA Outreach Trainer.3
• Hiring consultants specializing in worker health and safety.
• Attending webinars and in-person lectures addressing worker health and safety.
• Taking online courses specific to worker health and safety for the dental laboratory industry.
• Earning a degree in Occupational Safety and Health.
The topics that will be covered in this article are the Hazard Communication Standard; Respirable Silica Standard; Beryllium Standard; Recordkeeping, including Injury and Illness Tracking; and Bloodborne Pathogen Standard.
Hazard Communication Standard Update in 2012
Even though it has been 7 years since OSHA updated the Hazard Communication Standard4 to include components of the Globally Harmonized System (GHS), there are manufacturers who continue to provide the old Material Safety Data Sheet (MSDS) rather than the Safety Data Sheet (SDS) format. A best practice for a dental laboratory owner who is unable to replace an MSDS with an SDS is to write a letter to the manufacturer requesting the SDS. If there is no response, then the local OSHA area office can be contacted for assistance.
Another issue regarding providing availability of SDSs to workers is the retention of this information electronically. OSHA has issued interpretation letters5-7 describing the requirements to also have an alternate access in the event the Internet or a computer is not available when an SDS is needed. The alternative could include retention of all SDSs in hard copy format in a binder or a toll-free number with a company that provides this service.
Occupational Exposure to Beryllium and Beryllium Compounds
Over 40 years ago, OSHA established the permissible exposure limit (PEL) for beryllium. On January 9, 2017, the final rule8 was published by OSHA in order to replace the PEL that was outdated and did not protect worker health. According to information published by OSHA, they estimate "that the rule will save 90 lives from beryllium-related diseases and prevent 46 new cases of chronic beryllium disease each year, once the effects of the rule are fully realized. The rule is projected to provide net benefits of about $560.9 million, annually."
The Beryllium Standard applies to occupa-tional exposure to beryllium in all forms, compounds, and mixtures in general industry, except (1) articles that are defined in the Hazard Communication Standard that contain beryllium and (2) materials that contain less than 0.1% beryllium by weight where the employer can demonstrate that the exposure remains below the action level as an 8-hour time-weighted average (TWA) under any foreseeable conditions.
Overexposure to beryllium can cause chronic beryllium disease and lung cancer. It is estimated that about 62,000 workers are exposed to beryllium. Even though the standard addresses construction and shipyard workers, OSHA reports that the majority of workers affected are exposed to beryllium in general industry operations. Dental laboratories have been mentioned in some of the OSHA publications in the past.
The final rule had an effective date of May 20, 2017. For general industry, OSHA began enforcing most provisions of the Beryllium Standard on December 12, 2018. The exception was for engineering controls that must be complied with by March 10, 2020. The changes affect the following:
• A lower permissible exposure limit (PEL) of 0.2 µg/m3, averaged over 8 hours. The prior standard allowed a PEL of 2.0 micrograms per cubic meter of air.
• A new short-term exposure limit for beryllium of 2.0 µg/m3 over a 15-minute sampling period.
• An action level of 0.1 µg/m3 as an 8-hour TWA.
• Employers must protect workers by:
- using engineering and work practice controls (such as ventilation or enclosure);
-
providing respirators when controls cannot adequately limit exposure
- limiting worker access to high-exposure areas;
- developing a written exposure control plan;
- training workers on beryllium hazards; and
- providing (1) medical exams to monitor exposed workers and (2) medical removal protection benefits to workers identified with a beryllium-related disease.
The question of dealing with trace amounts has also been addressed. OSHA has not completely eliminated the exemption for exposure from materials containing trace amounts of beryllium because workers can still have significant (airborne) beryllium exposures even with materials containing less than 0.1%.
The new standard also provides detail regarding beryllium-contaminated clothing, hair, skin, or work surfaces and applies only where the contaminating material contains at least 0.1% beryllium by weight. The employer must ensure that practices are in place to prevent cross contamination between beryllium-contaminated personal protective clothing, equipment, and street clothes. Beryllium-contaminated personal protective clothing and equipment are not to be removed from the workplace. There are also restrictions pertaining to eating and drinking in areas where items such as clothing and equipment are beryllium-contaminated. The standard also cautions employers to not allow workers to remove surface beryllium from clothing or equipment in a method that would disperse the beryllium into the air or onto an employee's body. This would eliminate the use of compressed air and encourage the use of wet items for cleaning purposes, such as a moist paper towel.
In order for an employer to meet the requirements of this new standard, the employer needs to:
• conduct an assessment to determine if any materials used in their dental laboratory contain beryllium;
• assess the airborne exposure of each employee who is or may reasonably be expected to be exposed to airborne beryllium;
• install engineering controls to protect workers from exposure;
• implement a Respiratory Protection Program; and
• develop a written exposure control plan that contains all of the components listed in the standard at 1910.1024(f)(1).
Respirable Silica
Crystalline silica is a basic component of soil, sand, granite, and many other minerals. Quartz is the most common form of crystalline silica. Overexposure to silica can result in the lung disease silicosis. Silica can be present in the materials used in a dental laboratory to perform the following tasks:
• investing/divesting;
• mixing and grinding stone;
• sandblasting;
• mixing and grinding porcelain;
• mixing and polishing with pumice; and
• using a suction system for housekeeping and maintenance.
The Respirable Silica Standard9 1910.1053 required employers in general industry, such as dental laboratories, to be in compliance by June 23, 2018. Prior to the new standard the Permissible Exposure Limit (PEL) to silica was 100 µg/m3 (100 micrograms of silica per cubic meter of air) measured over an 8-hour day. The new PEL is half the prior PEL and is 50 µg/m3, measured over an 8-hour day.
The new standard also created an Action Level that is at or above 25 µg/m3, measured over an 8-hour day. Medical surveillance is required for workers at or above Action Level.
To meet the requirements of the Silica Standard, an employer must assess the tasks and operations in their dental laboratory to determine where silica is present. Then personal monitoring should be performed to determine the exposure level. After the results of the monitoring have been completed, the employer must take steps to eliminate or minimize the exposure to silica. These controls include the installation of engineering controls such as suction, guards, and shields along with administrative controls that may be to substitute a less hazardous chemical if possible. The final resort is to require workers to wear respirators and other personal protective equipment.
A written Respirable Silica Exposure Control Plan must be developed and the plan must be formally evaluated annually. This plan will detail the steps that the employer is taking to assess the hazards of silica exposure, methods to reduce the exposure, and ongoing evaluation of the effectiveness of the plan.
Recordkeeping
Back in January 2002, OSHA published a list of industries that were partially exempted from recording work-related injuries and illnesses. Industries are classified under the Standard Industrial Classification (SIC) code and dental laboratories are SIC 8072. However, there were some states with OSHA state plans that did not recognize that partial exemption; they were Hawaii, Minnesota, Nevada, and Washington. This changed in 2015 when OSHA changed some of the recordkeeping requirements.
One change was converting industry classification codes to the NAICS codes. Dental laboratories are NAICS code 339116. A list of high-risk industries was also published and the code for dental laboratories is included in the list of non-exempt industries.
This meant that dental laboratories with 11 or more employees began as of January 1, 2015, to use OSHA's forms 300 and 300A to record qualifying work-related injuries and illnesses. It is not always clear which injuries and illnesses are recordable. Employers need to educate themselves on what is recordable and what is not recordable. Only record on the forms the injuries that OSHA defines as recordable. To assist employers to make the determination as to the recording of an injury or illness, OSHA provides a Recordkeeping Advisor10 on their website. When using this Advisor, an employer will answer questions and then will be informed if the incident is recordable.
OSHA also changed the reporting requirements. The following incidents must be reported to OSHA within the timeframe noted:
• A work-related death must be reported to OSHA within 8 hours of the employer's knowledge of the death.
• Work-related hospitalization of an employee, amputation, or loss of an eye must be reported to OSHA within 24 hours of the employer's knowledge of the incident.
Businesses of all sizes must comply with the above reporting requirements within the timeframe indicated. State OSHA plans can require more stringent reporting requirements.
Injury and Illness Tracking
In order for OSHA to improve the accuracy of this data and identify establishments that experience high rates of occupational injuries and illnesses, a new electronic tracking system has been established.11 This submission requirement went into effect in 2017.
Establishments with 250 or more employees that are required to keep the OSHA injury and illness records and establishments with 20 to 249 employees that are classified in certain industries are required to submit this information annually. Dental laboratories in NAICS classification code 339116 with 20 to 249 employees must submit the information.
There are three options for data submission. The first is to manually enter the data into a web form. The second is to upload a CSV file to process multiple establishments at the same time. The last is an automated recordkeeping system that has the ability to transmit data electronically via an API (application programming interface).
Dental laboratories with 20 or more employees must provide OSHA with the prior calendar year 300A information each year by March 2. Your first step will be to set up your establishment if you have not already done so. Remember to retain the log-in information when you set up your account.
Bloodborne Pathogen Standard
The Bloodborne Pathogen Standard12 (BPS) became effective in 1992 as OSHA's answer to protecting healthcare workers from exposure to potentially infectious items. In a dental laboratory, these items include anything that is received from a dental client and has been in a patient's mouth. Dental impressions are the most common items.
The BPS requires employers to develop and implement a written Exposure Control Plan. This plan must be formally reviewed annually to ensure that the methods and practices established by the dental laboratory to protect workers from potentially infectious items are effective. Also, employees must be trained annually on these controls. These training records must be retained for 3 years.
Infection control procedures that have been established as best practices in a dental laboratory for the disinfection of these items should include the following:
• Use of an EPA-registered, hospital grade disinfectant with a tuberculocidal claim.
• Use of personal protective equipment (PPE) that includes a mask, eye protection, gloves, and a gown that covers street clothes.
• Rinse impressions prior to disinfection. The reason for this is that the dental staff may have disinfected the impression but did not rinse the impression prior to packaging it for shipment to the laboratory. Chemicals can have reactions that could be harmful for the impression material. Also, blood should be removed prior to disinfection.
• Following the instructions from the impression material manufacturer to determine the best chemical to use for disinfection purposes.
• Timing the disinfection process for the length of time to kill tuberculosis.
• Rinsing the disinfectant from the impression prior to processing into production.
After these items leave the receiving area, there may be other areas where additional disinfection is needed. For instance, if an overextended border of an impression is trimmed back in the model room, then a new surface is exposed. Disinfection should occur again. Also, any blade used to cut through the impression should be disinfected.
Another area of concern is in the model room where clinically poured models may be trimmed. If the dental staff did not disinfect the impression prior to pouring the model, there could be living viruses in the model. Technicians who are trimming impressions and models must wear the appropriate PPE and decontaminate any equipment or tools used in this process.
Processing of denture repairs can also present a risk of contamination. Technicians who are grinding on repairs or relines must wear appropriate PPE and decontaminate equipment and tools used on the dentures. The pressure pot is a perfect incubator for bacteria, so it should be disinfected after the dentures have been removed.
Since chairside services are more common these days, an employer must provide infection control training to technicians for their protection when in the dental office environment.
Summary
Employers must stay up-to-date with OSHA's requirements for the protection not only of their workers but also for the protection of their businesses' liability.
About the Author
Mary A. Borg-Bartlett
President
SafeLink Consulting, Inc.
References
1. OSHA: QuickTakes. United States Department of Labor website https://www.osha.gov/quicktakes. Accessed November 4, 2019.
2. OSHA: State plans. United States Department of Labor website. https://www.osha.gov/stateplans. Accessed November 4, 2019.
3. OSHA outreach training program: How to become an authorized trainer. United States Department of Labor website. https://www.osha.gov/dte/outreach/authorized.html. Accessed November 4, 2019.
4. OSHA standard interpretations: Hazard Communication Standard (HCS) requirements for Material Safety Data Sheets (MSDS). United States Department of Labor website. https://www.osha.gov/laws-regs/standardinterpretations/1996-10-28. Accessed November 4, 2019.
5. OSHA Hazard Communication Standard (HCS) requirements for Material Safety Data Sheets (MSDS). United States Department of Labor website. https://www.osha.gov/laws-regs/standardinterpretations/1996-10-28. Accessed November 11, 2019.
6. A centralized repository for the electronic collection and dissemination of MSDSs. United States Department of Labor website. https://www.osha.gov/laws-regs/standardinterpretations/1997-10-21. Accessed November 11, 2019.
7. Use of generic MSDSs written by third-party companies and employer responsiblities when using an online MSDS service. United States Department of Labor website. https://www.osha.gov/laws-regs/standardinterpretations/2007-03-07. Accessed November 11, 2019.
8. OSHA Beryllium Standard. United States Department of Labor website. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1024. Accessed November 11, 2019.
9. OSHA Respirable Crystalline Silica Standard. United States Department of Labor website. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1053. Accessed November 11, 2019.
10. OSHA recordkeeping advisor. United States Department of Labor Web site. http://www.dol.gov/elaws/OSHARecordkeeping.htm. Accessed November 4, 2019.
11. OSHA final rule issued to improve tracking of workplace injuries and illnesses. United States Department of Labor website. https://www.osha.gov/recordkeeping/finalrule/index.html. Accessed November 4, 2019.
12. OSHA Bloodborne Pathogen Standard. United States Department of Labor website. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10051&p_table=STANDARDS. Accessed November 11, 2019.