COMPLIANCE UPDATE APRIL 2019
WHAT’S IN THE APRIL ISSUE:
1. Who are the key regulators for dental compliance?
2. When is the best time to review your dental practice compliance?
3. EPA’s new Code of Practice for Ionising Radiation Regulations in Dentistry
4. Closing down the practice for the Easter break – things you must do!
5. Opening up the practice after the Easter break – things you must do!
Regulation, Patient Safety & Dental Compliance
Dentistry is operating in a world where regulatory monitoring and legal enforcement seem to be forever shifting. By way of assistance let me summarise the latest changes to impact on clinical dental practice.
The Health Information and Quality Authority’s (HIQA) mandate has recently been extended to include medical ionising radiation in both public and private dental installations www.hiqa.ie
The Environment Protection Agency (EPA) www.epa.ie
retains its existing regulatory responsibility for members of the public and occupational radiation protection, but some amendments have occurred to the new regulations.
As these new radiation regulations are at present in an implementation stage, dentists should actively familiarise themselves with guidance documentation on each regulators’ websites. The coming months will see the introduction of additional documentation regarding dentists’ obligations.
Infection Prevention & Control:
Health & Safety:
The Health and Safety Authority www.hsa.ie
has many regulatory responsibilities including identifying hazards in the workplace. The 2016 document on Occupational Hazards in Dentistry
is a useful guide for dental practices undertaking their scheduled risk assessments for Physical, Chemical Agent, Biological Agents and Psychosocial Hazards.
Demonstrating compliance with the legislation requires practices to have documentation on their policies, processes and procedures. This offers validated assurance to the regulator that quality and safe dental care is being provided.
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Dental Compliance – when is the best time to review your processes?
Recently a dentist/practice owner asked me to reschedule a planned practice compliance review until after a new dental nurse commenced work. Whereas this may have seemed a pragmatic approach I cautioned against it.
bad habits can set in from day 1. Trying to change behaviour is always an uphill struggle.
employers should prepare an induction training plan before any new employees start work.
newly recruited dental nurses require prompt introduction and training in practice protocols for infection prevention and control, health and safety, and emergency incident management.
newly recruited dental nurses should be allowed time to review this documentation. Then s/he should sign a statement indicating that practice policies, protocols and procedures have been read, understood and will fully comply with.
induction plans should promote effective and safe workplace integration by welcoming the employee and prepares him/her for their new role. Staff’s wellbeing is enhanced when they feel safe in their place of employment. Happy staff provide quality, safe care to happy patients.
Get it right from the start. The best time to review your dental practice’s compliance processes is before not after you take on a new employee.
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Dental Compliance Ltd recommends the EPA’s new dental code of practice click here
as essential reading for all dentists and dental team members. Dr Jane Renehan was the dental technical expert on EPA’S working group which wrote this code.
The EPA holds regulatory responsibility for workers and members of the public. This new code of practice is a helpful, practical guide setting out the requirements of the national regulator.
EPA’s remit as legislated for in S.I. No. 30 of 2019 should not be confused with HIQA’s radiation regulatory responsibilities.
HIQA was designated as the competent authority for medical ionising radiation (patients) under S.I. No. 256 of 2018. Refer to www.HIQA.ie
for information and relevant publications. Irish legislation provides for two separate competent authorities to act as regulators in oral radiology. Their individual remits are summarised in the table below.
- Dental chair and cart/delivery system: remove handpieces and 3-in-1 tips; flush, dry and wipe down the water lines, and clean down all surfaces including the base of the chair.
- Suction: remove salivary ejector and suction tip, flush suction lines, clean surface/bowls/manifolds, and change filters
- Water: empty the water distillation unit, disinfect/clean and dry all water storage bottle, place these empty in a cool place (preferably in a fridge)
- Countertops: clear all items off the countertops, store these over the holiday period in a dust-free clean area such as a cupboard, wipe clean all surfaces of counter tops, drawer and cupboard handles,
- Waste: remove and replace clinical and general waste bags, seal and tagged/labelled, store in a rodent-free secure area
- Consumables: restock all items in preparation for reopening after the holiday period.
- Electrical Equipment: switch off all electrical equipment especially pressure vessels such as autoclaves and dental compressors
- Office Equipment: Log off the computer, turn off monitor, wipe down the keyboard, wipe down the phone, and tidy the desk/administration area. Ensure all items which can be switched off are not on standby over the holiday period.
Allow extra time on the first day back at work to open-up the surgery and carry out the necessary checks and tests to start operating in a safe manner.
- Your most important check after an extended period of closure will be to your water-systems;
- Flush the dental unit waterlines for 2-3 minutes prior to commencing a patient treatment session;
- Even where it has been stored in a fridge distilled water should be used within 24 hours of being manufactured if its quality is to be guaranteed. In practices where water distillation units are in use this may necessitate using bottled sterile water until enough fresh distilled water has been produced;
- Where Reverse Osmosis systems are in operation run the RO machine for at least 20 seconds at the start of the day. Now check the water quality using your conductivity meter;
- Water in your taps and pipework may have stagnated over the holiday period. It is, therefore, good practice to run sink taps for a minute or two. This includes your non-clinical areas such as staff kitchen and the bathrooms. Freshen up the bathrooms by flushing the toilets.
- Regarding autoclave testing, it a good practice on your first day back to run your weekly vacuum test on the cold chamber. Then, time permitting, the steam penetration test-cycle can run with either a Helix / Bowie-Dick test. If time does not permit, the steam penetration test can be carried out during the first instrument sterilisation cycle.
- Turn on the dental compressor and suction motor. Observe these items running for a minute or two to ensure they are operating correctly.
- In clinical areas, such as the dental surgeries and decontamination areas, you should quickly look over the countertops and flat surfaces. If you think that dust has settled then carry out a quick wipe-down prior to repositioning stored items such as the dental curing light, amalgamator/capsule mixing machine, ultrasonic scaler etc. Check your stock levels of gloves, facemasks, paper hand towels etc.
- Finally, run a critical eye over the general external and internal environment of your practice. Check that waste bins don’t need emptying, and that the waiting room/reception area / public toilets are in order. (posters may have come loose or fallen down over the holiday period).
The above list is not exhaustive however I hope you find it a useful guide as you get back to work.