The SBDE has a new checklist spurred by the Tulsa Oral Surgeon embarrassment and a number of infection control issues in Texas and across the country. While the State’s checklist is not as detailed as our audit checklists the state’s checklist is still very relevant to you and your practice. You may say, "I’m running a ‘clean’ practice, so why does this matter to ME?"
Here’s why! The Dental Board is stepping up the number and frequency of office inspections… and for matters completely unrelated to OSHA or infection control complaints. Now, when the Dental Board shows up in your office to obtain records they may "hit" you with a Notice of Inspection. Their findings are fair game and they will certainly find some issues in your office (I know because I used to be "that guy")!
EVERYTHING the Dental Board and most government agencies investigate stems from a written complaint. This sucks for you because SBDE investigators may show up to investigate one matter and you may get busted for other issues completely unrelated to the original purpose for their visit (instead). You gotta ask yourself, "Have I covered my assets?"
Here is a sneak preview of the State’s actual checklist. Take a moment and use this to "check" your practice. Can you answer "Yes" to ALL of these following questions?
- Licenses displayed in view of patients
- Consumer Information sign in view of public
- Names of Dentists displayed at entrance
- Maintains Injury/Illness records (oddly, Dentists are not required to maintain injury/ illness logs as per OSHA regulations. The SBDE has no separate rule on this, but it made it to the SBDE checklist anyway)
- Equipment repair and maintenance logs
- Weekly spore testing records (at least two years’ worth)
- Written system of sterilization process monitoring
- Written process for managing semi-critical and critical items/instruments
- Written process for managing failed spore testing
- Written policies mandating use of proper Personal Protective Equipment
- Documentation of vaccinations offered to employees (Hepatitis B)
- Written policies regarding medical waste management
- Medical waste manifests from licensed medical waste disposal service (encapsulation not acceptable)
- Written policies and procedures for aseptic management during patient care
- Written policies and procedure for surface disinfection and environmental barrier protection
- Written policy and procedure for patients known to have communicable disease on arrival to your practice
- Do Dental healthcare workers (DHCW) wear utility gloves while handling contaminated instruments
- Suitable hand-hygiene accessible at point of need
- Operable eye wash station accessible
- Emergency drug kit with only currently-dated drugs
- Dental Unit Water Lines flushed for a minimum of 20 seconds between patients (even if you have anti-retraction devices installed)
- Treating Dental Unit Water Lines for biofilm
- Use of enzymatic cleaner prior to sterilization process
- Sterilization cycles verified with "internal" and "external" indicators
- Does the office refrain from overloading the sterilizer
- If applicable, does the office use an EPA-approved, high-level disinfectant for cold sterile
- Are splash shields and equipment guards used on Dental laboratory lathes
- Are fresh pumice and a sterilized rag-wheel used for each patient
- Are intraoral items such as impression molds, bite registrations, prostheses and Orthodontic appliances cleaned and disinfected before sending to Dental lab or providing to patients
This is a partial list of the checklist used by Dental Board investigators in Texas. As you will see they pretty closely mirror OSHA standards and the CDC recommendations for infection control. This a great opportunity for you to have access to the actual tools the state uses to evaluate your own practice.
I state with absolute certainty that a large majority of Dental offices, not just in Texas, but across the country, will have a good number of "No" answers to this checklist. If this is you, please let this serve as a wakeup call… a free gift just for you as a part of our spotlight on OSHA this month!