COMPLIANCE UPDATE September 2019
WHAT’S IN THE September ISSUE:
1. Update on Dental Amalgam Separators
2. Some basic design errors in reception/waiting areas
3. Quiz: what do these symbols mean?
4. Waste plaster/gypsum – what are the regulations?
5. Do you still need a Radiation Protection Adviser (RPA)?
6. Quiz: answers
7. Dental Compliance upcoming presentations on HIQA
Update on Dental Amalgam Separators
In the June newsletter, I covered these recent legislative changes. In summary, S.I. No. 533 (2018) obliges each Local Authority to monitor hazardous waste substances containing mercury in its area.
Inspectors will visit dental premises to review amalgam separators and associated waste-water discharge. It is now known that training of inspectors is planned in the coming weeks, with some pilot inspections due by year-end.
Dental practices are obliged to have amalgam separators installed and in working order which meet the ISO 11143 standard; removing at least 95% amalgam particles from used water. It is likely that your maintenance/service contract with an authorised waste management company plus a copy of your practice waste management policy as per by S.I. No. 126 (2011) will be requested by the Inspector. Keep these documents available for inspection.
In circumstances where practices produce no waste amalgam particles e.g. orthodontic practice, it is advisable to undertake a written risk setting out the justification for not installing an amalgam separator. File this assessment document in your practice Safety Statement.
Common infection control pitfalls in reception/waiting designs
“Wow” designs may look good but are they cleanable. Can you easily clean each and every item in the area?
If you can’t answer this question in one sentence then rethink your design!
Dental Council requires practices to have an Infection Prevention & Control policy covering clinical and non-clinical areas. True, there is a balance between giving patients a pleasant environmental experience and ensuring areas are clean. But if an inspector requests a copy of your cleaning protocol for soft furnishing, light fittings, indoor plants, shelves with ornaments or wooden panels etc. your document must be fit for purpose, plus evidenced that it is being carried out.
Consider finishing materials with care. For example with soft furnishings (seating, rugs, blinds) have them pre-treated with a hydrophobic coating so they can be easily wiped clean. Always choose larger broadleaf indoor plants as they can be quickly damp dusted.
Latticed/grooved wooden panels will hold dirt, so opt for flat surfaces. Ornaments should be easy to lift with one hand while the other hand dusts underneath.
Ask yourself “how do I clean it?” before finalising your interior design. Wow! and clean are not mutually exclusive.
Still, in doubt then get advice from an infection control design expert Dental Compliance would be happy to advise.
Quiz
What do these symbols signify? Answers are at the end of the newsletter
Safe Disposal of Gypsum Plaster & Old Models
Gypsum (calcium sulphate) is generally inert but given the right circumstances it can be highly absorbent.
Gypsum will generate hydrogen sulphide gas from microbial action when mixed with biodegradable waste, if it enters a normal mixed landfill.
Water brings about hardening, damage and eventually deterioration, releasing the hydrogen sulphide into the atmosphere.
This gas is highly toxic, malodorous and has serious ramifications for public health and safety, so appropriate disposal methods should be followed. Despite an existing EU Directive on this matter the legislation in Ireland does not specifically deal with Gypsum by-products in healthcare setting.
Recommendations:
- If you have large quantities of old models or you produce large qualities of waste Gypsum then ask your authorised healthcare waste company to supply you with an appropriate Gypsum Collection Bin. These bins come in a variety of sizes.
- If you have infrequent, small quantities of Gypsum waste simply include it in your clinical waste bags. These bags go for incineration.
- Never allow Gypsum or Plaster to be placed in domestic/general waste as routinely this goes to landfill.
Local Authority Waste enforcement officers will be visiting dental practices in 2020. They will initially be looking at Amalgam Separators (S.I. No. 533 of 2018). As an element of their inspection they may also inspect all other forms of waste, hazardous, general and recycling.
It’s a good time now to review your Waste Management Policy ensuring that if it applies to you that Gypsum disposal is included in your policy document.
Do you still need an RPA?.
With the changes to the Radiation Legislation earlier this year much confusion has arisen as to whether or not practices still require the services of a Radiation Protection Adviser.
This confusion is very understandable especially as it centres around a terminology/wording change in S.I. No 30 of 2019 http://bit.ly/2m4Oic2
Do you still need an RPA?
* Yes – but it’s now the case that you don’t need to hold a contract with an RPA;
* Yes – you are required by law to consult with an RPA on a list of items set out in the EPA’s Code of Practice http://bit.ly/2m80OYk
* Yes – you are required by law to undertake a biennial (at least every 24 months) Quality Assurance QA of your x-ray equipment along with consulting with your RPA to update your Risk Assessment and other specified documentation.
This a short version of what the new EPA legislation means for the person who was formerly the x-ray “licence” holder.
I haven’t yet mentioned what HIQA require from you by way of a Medical Physics Expert (MPE) services.
*Yes – this differs from an RPA
For more inform contact Dental Compliance.
Quiz answers
1. Corrosive Substance
2. Single Use Medical Device
3. Poisonous Substance
Dental Compliance Ltd supporting dentists:
- in-house compliance risk assessments
- practice-specific solutions
- advice surgery refurbishment design
- practical advice
- personalised/prioritised compliance plan
Dental Compliance Ltd saves you time and money
IDA Munster Branch Tuesday 17th Sept @7:30pm
Maryborough House Hotel, Douglas, Cork
Dr Jane Renehan
HIQA, Infection Prevention & Control and Dental Practice: what should we expect?
RCSI Autumn 2019 PostGrad Ed Prog
Saturday 26th October @8:30am Albert Theatre, RCSI
