Q: I updated my compliance manual last year; do I need to update it this year?

A: YES – if your compliance manual is written correctly and contains policies & procedures based upon all regulations and not just OSHA, then all you need to do is revise it as new requirements are released or working conditions change, at the minimum your compliance manual along with employee training is updated once a year.. With all due respect doctor, I evaluate about 55 dental offices each month and haven’t found one office with a correct compliance manual, what I have found was a lot of time and hard work put into a binder with incorrect results. Why would anyone attempt to take on a project that even experts find intimidating at times? If you think you are saving money I suggest you think again.

The mindset for dentistry is on OSHA where it should be on the Dental Board of California which is under Consumer Affairs. I am amazed to find dental offices focused on issues like labeling and MSDS binders more than sterilization and infection control. It is clear that the dental professional needs to become more aware as to what they must know and do regarding patient safety. Patient safety is paramount and it must be delivered consistently but only can be achieved when everyone is on the right page armed with the right knowledge. The Table of Permitted Duties and the Dental Board Infection Control Regulations is a good place to start! Visit the Dental Board’s websites: www.dbc.ca.gov

When it comes to dental compliance do you listen to those who know or do you listen to those who sell?

When choosing a seminar or compliance service you should select on the bases of getting quality how-to information from an expert, the kind of information and expertise that produces results and moves your office forward. Stop listening to those who sell gimmicks and produce nothing but BS.  This choice will cost you many times over in fines, citations, and litigation. Remember these two life teachings – “if it sounds too good to be true, it isn’t” and “you get what you paid for”

Q: Should my hygienists attend your seminar, they feel it is unnecessary since they get OSHA training at their other office they work at.

A: I wonder what your hygienists tell the employer at the other office they work at???

There is a lot more to dental compliance than OSHA, in my seminar OSHA is only 5% of the material I present.. I am amazed why dentist leave out key employees in meetings, trainings or seminars then think their office is compliant and everyone is on the same page as a “team”. I am also amazed why dentists allow their hygienists to refuse to follow policies & procedures or do things their way – are they not EMPLOYEES and are you not the EMPLOYER, get it?

Hygienists, why do you feel that you are above everyone else in the office and that there is nothing new to learn because you have infinite intelligence? How do you expect to contribute to the standard of the office and be a team player when you are not even close to being on the right page?

Now before I start getting a ton of hate email let me clear something up, my comments ARE NOT directed to ALL hygienists, I have worked with some of the greatest hygienists in the profession, these people in my mind are TRUE healthcare professionals of the highest caliber, they know who they are and they make-up only 2% of the hygienists population.

Bottom line, in order to be a Patient Compliant office that provides “Excellence in Patient Safety and Infection Control” every member of the team MUST be pulling in the same direction. Every member must add value to what they do, be able to teach others by example and themselves be teachable.

I am very busy working with new clients who had requested my services because their practice was inspected by OSHA or the Dental Board and the results were not favorable.  In the process of bringing these dental offices into compliance I discovered something they all had in common, they all had some type of compliance services or product which they relied on but apparently failed.  Here is the list,

1. Online OSHA training
2. OSHA training videos
3. OSHA monthly newsletter service
4. Attend dental associations seminars & conventions
5. OSHA training provided by a dental supply representative
6. OSHA training provided by their waste management company
7. Compliance Manuals which they download from a dental association
8. Compliance Manuals provided by their waste management company
9. Service from compliance service companies who guaranteed to pay any fines

Dental compliance training is a hands-on, show me learning process that should be conducted in your office by an expert.

Q:  I am thinking of having a member of my staff write our compliance manual, what are your feelings on this?

A:  A compliance manual is a complex project requiring research and specialized expertise.  When written properly it reflects the policies & procedures of your office based upon the guidelines and regulations from nine regulatory agencies.  Also it must be kept current as new regulations are published.  The fact is both time and money will be spent on writing your compliance manual no matter who does the work, the difference will be how long, how much, and the end results. To answer your question, I do not recommend writing your own compliance manual and I also do not recommend patients do their own dental work, instead seek the service of an expert.

Q: Are dental professionals required to have Healthcare Provider level CPR training for license renewal?

A: Although I highly recommend that all dental professionals, from front office to back get the Healthcare Provider level CPR training, the answer to your question currently is No.  Referring to the Dental Practice Act, Article 4, Chapter 1, Section 1016, mandatory courses required by the board for license renewal is the Dental Practice Act, Dental Board Infection Control Regulations 1005, and a course in Basic Life Support (BLS) CPR approved by American Red Cross or American Heart Association.

When it comes to patient safety the best training and the best skills is paramount – for onsite CPR Training in the Greater Bay Area, I recommend contacting Roland Guy at Critical Care Solutions, 916.226.6053, visit their website: www.criticalcaresolutions.com

Q:  Are onsite seminars better than attending an open seminar?

A:  When it comes to compliance and infection control training I believe onsite seminars offer a huge advantage over open seminars. Think about it – using your office as the model, an onsite seminar now becomes personalized training and hands-on guidance that produces immediate tangible results, something that cannot be accomplish while sitting in a conference or meeting room. Don’t get me wrong, open seminars provide valuable information and positive learning environments, I personally conduct 22 open seminars each year, but some critical skill concepts must be shown and not told; it’s like trying to do dentistry over the phone.

Your Compliance Manual should contain current, site-specific policies and procedures for establishing and maintaining a safe working environment.  In addition, training documents, rosters, and audits/inspections reports should be filed within the manual. Your Compliance Manual should never be a “junk collector” for seminar handouts, advertisements, and unrelated documents, if your manual is a confusing mess don’t except anyone to read it and use it. All employees must be familiar with the policies & procedures of the office therefore they must review the Compliance Manual and postings.

Management must keep policies & procedures current and enforced, during an inspection the inspector will review the Compliance Manual, Posters, and postings to determine if policies & procedures for compliance are established and enforced.  The inspector will interview employees, if simple questions get answers like “I think we do”, “I’m not sure”, or “I don’t know”, the inspector will come to a quick conclusion that compliance doesn’t exist; this is not a good thing!

The fact is that 9 out of 10 Dental Offices fail OSHA inspections and receive huge fines, how will your office do? If you answer “NO” to any of theses questions, prepare yourself for the OSHA inspection from hell!

• Has your compliance manual been revised for 2010?
• Do you have a written Exposure Management Plan that is current?
• Do you have a written Injury and Illness Prevention Plan that is current?
• Do you have a written Hazard Communications Plan that is current?
• All employees both part-time and fulltime received in-office training on Bloodborne Pathogens Standard every year?
• All employees both part-time and fulltime received in-office training on Injury and Illness Prevention every year?
• All both part-time and fulltime received in-office training on Hazard Communications every year?
• Do you have documentation for all employee meetings and trainings?
• All employees are following office policies & procedures?
• Management enforcing office policies & procedures?