Five things you should do during inspections,

1. Ask questions
2. Take notes and photos
3. Don’t argue with the inspector
4. Walk around with the inspector
5. Ask the inspector for their suggestions

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.

Q: What governmental agencies are most likely to inspect our office?

A: Although there are about seven agencies that are responsible for regulating dental offices, the top three and most active are,

1. OSHA
2. Consumer Affairs (Dental Board)
3. Department of Health Services

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:  Do I need a Medical Waste Generator Permit even if I have an EPA number?

A:  YES – based upon the Medical Waste Management Act, most if not all counties in California require healthcare businesses that generate medical waste, i.e., sharps, biohazard wastes, etc., be registered with the Dept. of Health Services division of Environmental Health in the county which the practice is located.  A “Medical Waste Generator Permit” which has nothing to do with the EPA permit, will be issued once the registration process is completed.  Determine if a permit has been issued, if not, contact the Dept. of Health Services division of Environmental Health in your county (government pages of telephone book) and request an application packet.

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

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!