Oral Health Group
Feature

Regulating the Regulations

March 1, 2011
by Janice Goodman, DDS


When I built my office, I don’t think I gave that much thought to rules and regulations that were imposed from groups other than the College of Dentistry. I relied on the company that set up my office to make sure that things like the X-ray machines and sterilizing equipment were up to standards and to let me know what I had to do to stay out of trouble. Gradually, over the years, a lot of interested parties have imposed more and more regulations to the point that I doubt there is a dentist in the country who is fully aware and has implemented all of them. Lately new audits have been imposed on our offices. We need to have our provincial licensing bodies or dental organizations provide us with comprehensive check lists that are kept current of what is expected of us, and what the penalties are if we are not in compliance.

Dr. Harold Berenstein (a Tor­onto dentist), recently published an article in the December 2010 Aorta titled “Ontario Min­istry of Labour Audit.” I appreciated him taking the time to share his experience with other dentists and with his permission I am repeating some of it here. Dr. Berenstein was the lucky winner of a random inspection by the Ontario Ministry of Labour. Having been quite concientious in trying to comply with city, provincial and federal by-laws, his office was now being examined. Violations that were cited included not posting an “Occupational Health and Safety Act and Regulations for Industrial Establishments” sheet in plain view for all employees to read; an eyewash station to augment his first aid kit; all chemical products had to be inventoried and monitored monthly by a staff member; polishers and grinders had to have a safety shield that complied with what was required; boxes could not be stacked too close to the ceiling; one of his two oxygen tanks had to be bolted to the wall (the other being on a trolley) and information had to be posted about steps to be taken in the event of an accident. Luckily he had just updated his office manual and had complied with the requirement of managing and preventing sexual harassment and violence in the workplace, but, he was told that he had to review this material routinely and record the dates in the manual when it was done. I should point out that Dr Berenstein was not fined by the Ministry and he was given a period of time to become compliant with their requests. In addition he had to host an afternoon lecture on safety on the workplace given by OSACH (Ontario Safety Association for Community Health Care) at his own expense.

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The Ontario dental hygienist college is doing similar random visits in dentist owned offices and making lists of requests. These random visits are extremely disabling and unnerving for a busy office. Are we going to be visited by the dental assistants’ association next? How about the dental technicians’ association…after all we do share cases…should we not have to be up to their standards?

I would like to appeal to all the different groups that have the ability to force an audit on a dental office. I suggest that they let the office know exactly what they will be looking for and give them plenty of time to be compliant. If they want posters to be placed in plain view for employees, they should send them to offices on a regular basis and tell them exactly where to place them. If they want manuals and maps of where and what is in the office, perhaps they can help out by providing standardized ways of doing it. Rather than just passing a by-law and expecting the dentist to know about it, perhaps they should have to be responsible to inform each dentist on a regular basis directly. Some agencies have done this well (e.g. amalgam waste in Toronto – every office gets notices from them that this is the year to send in compliance forms and includes the actual form)…it is unfair to expect a dental office to do certain things annually if you don’t remind them. When I get a notice that something has to be done, it has a better chance of happening than if I don’t get a notice. I commend all the bodies involved that appreciate that these are sensitive issues and the vast majority of dentists want to be as compliant as possible. I also challenge the organizations that are setting the standards and guidelines to be helpful in facilitating the implementation of them. The WHIMIS Programme required dentists to use Safety Engineered syringes…most dentists had no idea what they were talking about. It meant each dentist had to research the subject and make some changes in their offices. It caused a reasonable amount of anxiety. How much individual help did the Ministry provide and how many dentists became compliant?

For me, these changes have come gradually over the years and so I was able to implement most of them. Sometimes I only learned about them while lunching at meetings with other dentists. It must be overwhelming for a new dentist to graduate and be faced with all these regulations. Good luck to them!OH