COMPLIANCE UPDATE June 2019

WHAT’S IN THE June ISSUE:

1. Report from HIQA stakeholders’ forums
2. Introduction to your Safety Statement
3. Quiz: what do these symbols mean?
4. Personal Protective Equipment & Uniforms Advice
5. Standard Operating Procedure (sample) for sharps container
6. Regulator appointed for Dental Amalgam Separators

Report from HIQA Stakeholders’ Forums

The Health Information and Quality Authority (HIQA) who became the Competent Authority for regulating medical exposure to ionising radiation in January 2019 recently held a number of stakeholder briefings in Dublin, Galway, and Cork. The purpose of these events was to provide professionals with an opportunity to meet HIQA and listen to presentations outlining their regulatory plan.
As an attendee I found the content of these presentations to be very generalised, covering the widest variety of healthcare facilities where exposures are made and an equally diverse range of radiation procedures, ranging from high-risk complex medical procedures to the low-risk but high-frequency dental radiographs.

The take-home messages were:

    1. It is essential for undertakings to be familiar with the 5 publications which HIQA has issued since January. Click here for the direct link to these documents on www.hiqa.ie
    2. Dentists and other members of the dental team that made ionising exposures but who are not undertakings were reminded that they too have responsibilities under the legislation S.I. 256 of 2018. HIQA places the onus on individual practitioners to inform themselves of these obligations and to practice within the legislation.
    3. Dental practices must establish and document their site-specific governance structure setting out each individual’s level of authority and responsibility. All staff should be made aware of where they and other team members sit within their practice governance framework.
    4. HIQA advised where there is a CBCT (cone beam) unit these dental practices will receive a radiation self-assessment questionnaire in September/October 2019. This will comprise of no more than 20 questions confirming the undertaking’s compliance with the legislation. Based on a practice’s answers HIQA may then request supporting evidence of compliance. Announced inspection for practices with CBCT units should begin by the end of this year.
    5.  All other dental undertakings will receive a similar style of self-assessment questionnaire and announced inspections in 2020.

Safety and health at work

Dental Practice Owners are obliged to manage safety, health and welfare in the workplace for their workers and members of the public.

The law requires employers to:

  1. Identify the hazards
  2. Carry out a risk assessment
  3. Prepare a written safety statement

What is a Safety Statement?

This is a written programme to safeguard the safety and health of employees and others who might be at the workplace e.g. patients, members of the public, service engineers etc. The safety statement represents a commitment to their safety and health and should influence all work activities.

Writing down the safety statement, and putting in place the organisation and arrangements needed to implement and monitor it shows to staff, and anyone else, that hazards have been identified and risks assessed, eliminated or controlled.

Employers must ensure that the relevant contents of the safety statement are brought to the attention of your employees and other affected at least annually, and whenever it is revised.

www.hsa.ie has a range of useful guides – start by checking out here 
Contact us if you need assistance with your risk assessments and safety statement

QUIZ: on your hand hygiene facilities

What do these symbols signify? Answers are at the end of the newsletter

Personal Protection & Personal Protective Equipment (PPE)

The Dental Council Code of Practice states that it is mandatory for all staff to wear appropriate personal protective equipment (PPE) when performing out infection prevention and control procedures. Hand hygiene must be carried out after the removal and disposal of PPE which includes gloves (including heavy duty gloves for manual washing of equipment), surgical face masks, visor/protective glasses/goggles and uniforms/scrubs/gowns. Many PPE items are single use (ref manufacturer’s instructions).

Where to wear: It is best practice that uniforms are not worn outside of the dental premises. Where it is not possible to change the uniform when travelling to and from work every effort should be made to fully cover the uniform while in transit. It is poor practice to carry pens, scissors, and phones in outside pockets.

Tunics/Gowns should be bare below the elbows to facilitate correct hand washing techniques. Personal items of clothing such as cardigans and waistcoats should not form part of the uniform.

Shoes should be appropriate for the workplace with non-slip soles. The uppers should be solid to prevent a sharps injury and to protect against chemical spillage. Open toe footwear and canvas uppers are not advised.

Washing: Change immediately if the uniform becomes visibly soiled or contaminated. It may be washed in a domestic washing machine along with other clothes. A temperature of no less than 60 degrees for 10 minutes is suggested as appropriate. Daily change of uniform is recommended.

Finally, it seems unlikely that uniforms are a significant source of infection control nevertheless how dental team members dress sends messages to the patients they care for. Patients expect staff to have a neat appearance with a sloppy appearance being taken to poor infection control standards in the practice.

SOP (sample) for the Management of Sharps Containers

Introduction:

The purpose of this SOP is to ensure a safe and standardised approach to the assembly, use and disposal of sharps containers in your dental practice.

Assembly:

  • Lid must be securely attached to the base of the container – there should be an audible click when the lid is in place and it must not be possible to remove the lid. (photo 1)
  • The ‘Assembled by’, section on the container must be legibly completed and dated.
  • The lid should be placed on the container so that the opening is directly opposite the handle
  • The sharps container should be hung or fixed in a rigid holder in the surgery to reduce the risk of spillage. It should never be placed on the ground.

Use:

  • A list of items to be disposed of as ‘sharps’ should be set out in the practice Infection Prevention and Control document
  • The lid should be slid across (‘Temp’ mark aligned with ‘Close’ on the lid) over lunchtime and at the end of day (photo 2)
  • The sharps container must not be filled above the line marked on its external surface
  • The generator of the sharp is the person legally responsible for safely disposing of the sharp into the container.

Disposal:

  • When the sharps container has been filled the lid must be closed permanently before removing it from the wall mounting – there should be an audible click when the lid has been securely closed and the ‘Final’ mark will be aligned with ‘Close’ on the lid– This must be carried out before the container is removed from the dental surgery for disposal. (photo 2)
  • The ‘Closed/Disposed by’ and date sections must be legibly completed. (photo 3)
  • The closed container should be tagged, and the number of the tag must be recorded in the contaminated waste disposal log ready for collection by a licensed hazardous waste company.
  • Closed sharps containers must be stored in a secured, locked facility with no public access.

For more information read the Health and Safety Authority guidelines here.

Dental Amalgam Separators – how to comply with recent legislative changes

SI 533 of 2018 designated the Environmental Protection Agency as the Competent Authority for oversight of hazardous waste substances containing mercury with each Local Authority monitoring the dental practices in its area.

Although it is not yet known how this monitoring will operate it would be reasonable to assume that some form of a review of amalgam separators and associated waste-water discharge from dental surgeries will be undertaken.

Dental practices are obliged to have amalgam separators installed which are CE marked and meet the ISO 11143 standard; removing at least 95% amalgam particles from used water. A maintenance/service contract with an authorised waste management company should support this unit.
Documentary evidence of compliance is a fundamental requirement of any Regulatory Authority. It is advisable that this is held to hand, available for the inspector’s visit.

In circumstances where practices do not produce waste amalgam particles e.g. an orthodontic practice, it is advisable to undertake a written risk assessment set down the justification for not installing an amalgam separator.

Further info and assistance: www.dentalcompliance.ie

Quiz answers

1. Biological Hazard

2. CE marking for Medical Devices

3. Radiation Hazard

Dental Compliance Limited supports dentists by carrying out on-site practice assessments and providing solutions that are practical and effective.
Our mission is to save you time and money by doing your compliance work for you.