Charles John Palenik, MS, PhD
Compliance with patient and employee health and safety issues often appear to be complex, costly, and, at times, confounding. A variety of federal, state, and even local governmental agencies have released sets of regulations, standards, and rules. Other agencies and professional organizations have developed guidelines and procedural lists. Dental offices have been told that they must create and maintain a number of written exposure control plans, keep multiple employee records (for example, occupational exposures, vaccinations, and training), and conduct product safety evaluations.
The process often leads to confusion, sins of omission and commission, and misallocation of valuable resources (time and talent, as well as treasure). In spite of a good faith effort by most, results often can be uneven - too much concern in some areas, little or no effort in others.
An unenviable task for any sunny Saturday morning would be the cleaning out of an overfilled attic, closet, or basement, or assimilating all those little pieces of paper needed to complete a tax return. Organizing an office infection control program is a similarly daunting task. So, where does one begin?
It helps to have a clear and correct picture of what the final product of your efforts should be. A simplified outcome of health and safety compliance could be the creation and maintenance of a safer working environment for patients, employees, contract workers, and the surrounding community. However, there usually is a discrepancy (a gap) between what is desired and what is actually occurring. Expressed as an equation, this would be optimal - actual = performance discrepancies (better known as needs). Once compliance needs are identified and defined, the dental office is ready to act. For some offices, this may be an extensive venture, while for others a review will help assure that needs have been addressed.
To best deal with health and safety compliance, a scheme of five interrelated elements commonly used for instructional systems development can be employed. These elements are analysis, design, development, implementation, and evaluation.
Analysis asks the basic question, "What are the problems?" Gaps, deficiencies, and needs must be identified and described in real terms. A search for the causes of the problems is also essential. Combined, these actions should offer insight on to how best address the problems.
We often prepare goals for ourselves, our workplace, and even our children. However, all goals and objectives must have measurable outcomes. The office compliance program must be designed so that its intent is clearly defined and correct, yet reasonable. It must answer the question, "What are the expectations?"
Employees and employers must acknowledge that both parties have rights and responsibilities. Without responsibilities, there can be no rights. It is the responsibility of the employer to provide leadership and resources that help attain a safer working environment. In turn, it is the duty of employees to comply with the tenets of an office's health and safety program. Chances of success usually increase when employees become actively involved with planning and implementation.
During development, decisions are made on how to best achieve the goals and objectives of the office compliance program. This process is also called "task analysis," or the generation of a prioritized action plan. All of the necessary resources must be identified and obtained.
Implementation is the actual trying-out of the actions produced from the needs and task analyses. Increased success can be realized if office personnel have been prepared for change and if performance expectations have been placed in writing and reviewed by everyone.
Few plans are perfect, especially at the start. So, it is necessary that a system of review be established. Evaluation answers the question, "Did it work?" If not, then "Why not?" Areas of success can be retained; issues requiring improvement need alternative design and development. This is not purely an academic exercise. Current regulations and recommendations demand that offices regularly monitor, review, and, when necessary, change their compliance programs.
The organization of a health and safety compliance program cannot be accomplished in a single monthly column. Additional topics (for example, actual rules and regulations, identifying responsibilities, establishing a functional team, and design and execution of a program) will be addressed in the next four issues.
Today, most compliance related materials, including standards, background, forms, and templates can be obtained electronically. Valuable compliance materials can be secured from reliable agencies and organizations via their Web sites:
- The Organization for Safety and Asepsis Procedures (OSAP), www.osap.org
- The Centers for Disease Control and Prevention (CDC), www.cdc.gov
- The Occupational Safety and Health Administration (OSHA), www.osha.gov
- The American Dental Association (ADA), www.ada.org
This article was developed as a resource from OSAP, dentistry's resource for infection control and safety. For more information on CE opportunities, please contact OSAP at (800) 298-6727 or www.osap.org.
Dr. Charles John Palenik is an assistant director of Infection Control Research and Services at the Indiana University School of Dentistry. Dr. Palenik has authored numerous articles, book chapters and monographs, and is the co-author of the popular Infection Control and Management of Hazardous Materials for the Dental Team. He serves on the Executive Board of OSAP, dentistry's resource for infection control and safety. Questions about this article or any infection control issue may be directed to [email protected].
