OSHA and CDC Latest Guidance: How it Effects Your Practice

You're listening to The Dr. Phil Klein Dental Podcast from Viva Learning.com. Welcome to the show. I'm Dr. Phil Klein. Today we'll be discussing the latest guidelines from OSHA and the CDC for infection control compliance and how it affects your practice. Our guest is Dr. Karson Carpenter, a practicing dentist who serves as president of Compliance Training Partners. He is an OSHA-approved trainer. who has for over 25 years designed educational programs to bring dental and medical facilities into compliance with governmental regulations, including OSHA, HIPAA, and infection control. Before we get started, I'd like to thank Cranberry for sponsoring this podcast. Since 1988, Cranberry has specialized in the development, manufacturing, and distribution of premium protective infection control solutions. So we thank you, Cranberry. Dr. Carpenter, it's a pleasure to have you back on our show. Phil, it's great to be back. Thank you for having me. Yeah, so OSHA and infection control compliance requirements have been evolving quickly this year. You've covered some of that in previous podcasts. What's the latest? What's going on? Well, you know, it's really good that we're having this one today because it wasn't that long ago when we talked before, but already things have changed a bit. Since we last talked, of course, Delta had... really uh surged has really surged it's starting to look a little better but it surged a lot since our last talk and of course the emergency temporary standard from osha i want to talk about that as well as the latest guidance from cdc now remember when it comes to osha osha's guidance is to protect employees they're not really concerned about our patients they're concerned about dental workers and what they said is this of course they had an emergency temper have an emergency temporary standard that was promulgated during covet right to protect workers and they said this dental offices can be exempt from the emergency temporary standard if they do certain things okay now the main thing that they would have to do would be they would have to be a facility that does not work on known or suspected COVID-19 patients. And really, that's everybody, I think, that's listening to this podcast. Unless you work on suspected and known COVID patients, have a negative air pressure room, filter your air with HEPA filters, I don't think most of us are doing that. So what I'm telling you is that if you screen everybody who comes into that facility, according to OSHA, that means not only patients, but staff. people who repair your equipment, you're exempt from the emergency temporary standard. But that does not apply to those offices that are still in an area where it's considered fairly dangerous, which is a rating that OSHA provides, right? Can you tell us a little bit about that? You're right, and that's part two of it. What they say is that you're exempt from the emergency temporary standard, and now you can determine, based on your professional judgment, what the transmission levels are in your community, and then decide which PPE you should use. And here, remember always that OSHA and CDC kind of blend together sometimes. And how do you determine what's the level of transmission in your community? How do you know what protective equipment you need to wear? Well, what you do is you go to the CDC's COVID data tracker. And that's something you might want to write down, people who are listening. Just Google it up, CDC COVID data tracker. You'll then be able to find the level of transmission in your community. And you're going to either be low, moderate, substantial, or high. And depending on where you're at, you can choose the proper PPE. Now, is there some sort of protocol based on what rating your community is in at the time? Is substantial and high, is that a criteria for N95 masks? Let me explain just how it works. Here's what the guidance would say. First of all, step one, we know we are exempt from the emergency temporary standard because we're not working on suspected patients. Number two, we've looked up our, and we're screening everybody that comes in also. We're screening everybody. That's number two. The second thing is that we're looking up our level. If we are low to moderate, we can basically practice the way we used to with surgical masks, level two, level three masks, safety eyewear, like safety glasses. We can do things the way we used to. On the other hand, if we're in a community that has substantial to high transmission, now we do need to wear N95s and full face shields if we're doing aerosol generating procedures. Okay, so that is much clearer. What are some of your tips that you offer your clients? And I know you do a lot of training through your company, Compliance Training Partners, which has been a very successful company for you over the years, of which you're president and I believe founder. What are some of the tips that you provide your clients regarding simplifying compliance? Of course, we're all in a busy practice and the dentist is busy enough with all the other things he or she has to do. What do you suggest to the practice as a whole so that... can get to that simplification process? Well, the first thing that I find, I don't know that I've ever seen a practice that's in compliance unless somebody was assigned to do it. I would say pick a trusted clinical person, so an assistant or a hygienist, somebody in the back office, to be your OSHA compliance slash infection control coordinator. That's the person who can make sure that you have a compliance manual. that people are trained as part of the onboarding process, that annual training is scheduled. And I'll give you an example with the COVID things we've just talked about. That would be the person who would once a week go to the CDC COVID data tracker and see where you're at. You may find all of a sudden last week you were in a substantial transmission, had to wear N95s. This week, You're in a moderate and you can go back to level two or three. So that person can keep you on point. And then you can use your professional judgment to decide what type of PPE you need. Right. And this is really important because now you have someone in the office who's accountable. And having that person who's accountable is also responsible for the safety of the patients and the workers, the team. the office from using an n95 mask and disposing of them for each patient which is what regulation says to do versus a level three mask i mean isn't that a huge savings and cost right there you know it is a cost savings but to me and to my colleagues that i talk to more than the cost differential it's the time differential um to put on an n95 properly to do a seal check every time to do the uh once a year fit test um and then when you work if you've um if you've ever worked on a patient with an n95 and a full face shield the whole process is just a bit slower so so to me it's almost time more than the cost of the product exactly right but as we always say time is money and yes so yeah this is all has to do with cost um you know of course uh not having to say that the most important thing is safety that person who's in charge could essentially keep the office safe and also cut down as you said on the time spent on PPE, wearing it, setting it up, inventorying it, all that stuff is costly when it comes to time and that adds up into dollars that hit the bottom line. And it's also a way of practicing. Nobody wants to walk around with a face shield and an N95 if they don't have to. It's just something that's not that enjoyable to do on a daily basis with everybody. Oh, you're right. It is not. Sometimes it feels like practicing underwater. Right. The other thing I wanted to ask you is the kinds of PPE that we're wearing. And I know some offices look for bargains in different places to buy gloves in large quantities, maybe from out of the country. Same with masks. Tell us about your thoughts on that. Is it that crucial if we're throwing a lot of this stuff out after single use? Does it really matter when it comes to some of these things? And what do you advise your clients when you... work in compliance training partners about the kinds of products that they have in their practice? Well, you know, I advise people that first of all, they need to buy quality products. Quality products sometimes cost a little more. Sometimes they don't, but sometimes they cost a little bit more. But the key thing is a quality product to me means when you can, you're buying from the same company time and time again, a product that fits, a product that's comfortable, then the staff will use it. You'll find these cheap masks. that are miserable to wear. They don't protect you. They don't protect the patient. And you'll see staff doing things like not cinching them around their nose or pulling them down below their nose. So look for a quality product. When you find a quality product that fits well, the size is right, stick with it. And also tell us about the different ratings of the masks that may not be either accurate or even printed on the packaging of some of the other brands. Another reason to buy a quality product, mask, gloves, and I'll mention our sponsor, I'll mention Cranberry, because if you're buying one of their masks, you're going to see that the masks have the ASTM level right on the box. So you can tell, do you have a level one, a level two, a level three mask? A lot of the cheap online products you buy, they're not really compliant and they don't protect you and they don't protect the patient. To recap some of the things that you brought up here. So right now in the state that we're at now, we're in October, early part of October 2021. We don't necessarily have to wear N95s for aerosolized procedures if we're exempt. And that means that we're screening everybody that comes in the door, patients, people that come into service or computer, whatever it is, we're screening them. We have documentation that we're not treating patients that have COVID. Plus, if you follow that tracker that you mentioned and you're not in a severe high, I think you mentioned high and substantial levels, if you're not in those categories, you do not need to wear an N95 and you can pretty much practice the way you did prior to the pandemic, except for the fact that you're screening. Is that right? Absolutely. You're correct. The key is that you're in a low to moderate transmission situation in your community. So what worries you about the way offices are going to do things as the pandemic wanes, as we back out of this and we have this feeling of, okay, we're in safe zone now. We're getting a little bit complacent. We certainly all went through COVID fatigue in the dental practices. I mean, for God's sake, what these dental practices had to go through. especially during the peak of it in March of 2020, it was just unbelievably difficult. The stress, the uncertainty. So we're all relieved that it's waning. Maybe it's going to be six months from now, whenever that period is. What worries you about the way dental practices might continue with their protocol? You know, I'm glad you asked me that because that's definitely a concern I have is where we're going. And my word to my colleagues is, Don't let your guard down. Some of the statistics I've seen, general population in this country, about 9% of contracted COVID. Physicians and nurses, close to 25%. Dentists, about 2.7%. And I want to keep that going. Don't let your guard down. We still have COVID out there. We still have the Delta variant. So don't suddenly say it's over. And particularly as we get down the road even a few more months, follow that CDC guidance. They'll let us know when we can go back to all practicing the way we used to. So be careful, remain vigilant. We have an incredible record in dentistry. There's actually no clusters of COVID coming out of a dental office in this country. Yeah, I think that's great advice, Dr. Carpenter, because recently I read an article saying that this unknown virus, this new virus that has really just shook up the world, has a cycle that's very... puzzling and baffling to scientists and epidemiologists where the cycle runs two months, you get some waning and it looks like there's the hospitalization rate is going down. It looks like things are getting under control and then boom, it surges again. And this has happened several times. Of course, the variant has contributed to this, but just because things look like they're changing for the better, it doesn't mean something's not brewing in the background, which is pessimistic, but let's be cautiously. optimistic i guess we should be right maintain i think you're being realistic we just don't know we've never faced this before we're coming into winter the doors are being closed um yeah things look better but but we we don't know and the reason i i asked my colleagues to do this i know it's not fun to have to practice with an n95 and have to spend the money on this but think of the liability from your business for your business from employees that could challenge you, from patients that could challenge you. We don't need that to happen to you. Yeah. And last question, actually, as we wrap up this podcast, and it was an excellent one, Dr. Carpenter, we appreciate your time as always. What's the latest way to deal with vaccinations among your employees? How do you handle a dental office that has 10 employees, the owner of the practices? Could they make it a mandate that the employees are vaccinated? And do you have to reveal this to a Patient, if they're not, how does that work? You know, this is a really interesting and touchy area, and we get questions about it at compliance training partners all the time. We get those calls almost every day. And here's the situation. First of all, I like the fact that we can use our professional judgment. Myself, my feeling is that in a dental practice, I feel that everybody should be immunized. I feel that all my staff members need to be immunized. If not... shouldn't work there. Now, the reason I like that is then when the patient says to me, are all your staff members immunized? I can say, yes, they all are. I don't have to play the game of, well, we're following CDC guidelines. I can't divulge that. I mean, I don't like to play that game. If you, on the other hand, decide, look, I've got some key staff members. I need to keep them. They won't get immunized, even though I've really educated them why they should. Well, at that point, If a patient asks, you certainly can't tell them, yes, everybody's immunized. That would be a lie. Instead, you would have to say, I can't divulge that, but we are following all CDC guidance. Or right away, the patient knows what? You've got unimmunized people. It's an area without a perfect answer. Yeah. Well, that's good. I mean, at least you're trying to educate your employees in your practice. about getting immunized. And there's two sides to it. I mean, some people feel there's not enough data out there. And there are some cases where immunization caused some issues. But for the most part, it's been proven to be very safe. And it certainly has protected millions of people in this country from getting sick. So thank you, Dr. Carpenter. It's been a pleasure having you on the show. For more information about Cranberry, our sponsor, feel free to Google Cranberry. If you want more information about Dr. Carson Carpenter, and his company, Compliance Training Partners. Feel free to visit his website at compliancetrainingpartners.com. And I believe you have some free downloads, Dr. Carpenter, on that site. Certainly, I'd advise everybody who wants to know more about this. I love audit checklist, and we have an audit checklist for infection control, an audit checklist for OSHA, and that's free for anybody to just go to and download. Dr. Carpenter, we hope to see you again on another podcast or webinar by Viva Learning. Thanks very much. Phil, thank you. Great to talk with you again.