Qualifying Your Safety Program Under the CDL Requirements
Qualifying Your Safety Program Under the CDL Requirements
The National Board for Certification appointed a committee several years ago to review the requirements for a dental laboratory to become designated as a Certified Dental Laboratories. The CDL modernization committee established the criteria for dental labs for their initial application and for their five-year revalidation application. NBC issued a photographic checklist and a more detailed explanation of the physical facility requirements, equipment requirements and managerial requirements. Photos are to be submitted to show compliance with all of the applicable requirements. As a member of that committee and as a safety expert, I have been asked to provide a more detailed explanation of the physical facility and equipment requirements to assist dental laboratories in submitting appropriate photographs for compliance with these areas.
Physical Facility Requirements
a. First Aid Kit: The requirement for a first aid kit is to have on hand the supplies appropriate to treat the type of injuries that can occur in the dental laboratory, i.e. bandages, first aid cream, burn cream, alcohol wipes, gauze, etc. Most dental laboratories do not employ a licensed healthcare provider, therefore, medications, even over-the-counter medications such as aspirin, Tylenol, etc., should not be provided by the dental laboratory. There can also be legal and liability issues when making these types of medications available. The photo should show a distance shot of the location of the first aid kit and the sign showing its location. Another closer-up shot of the contents of the kit must be provided . A first aid kit may be located in a cabinet and, if so, then a sign on the outside of the cabinet door is required.
b. Emergency Equipment: The eye wash station or stations must be shown in the photos. If more than one, submit photos of all locations. The photo should provide the reviewers a view of the eyewash and the location. The eyewash must be ANSI approved and preferably single-action type. If a faucet-mounted eyewash is installed, then it is even more important for no hazardous chemicals (acids for instance) to be used at this sink and no hazardous equipment (steam cleaner or other hot equipment for example) installed close enough to impair safe access to the eyewash. If an eyewash is located in the infection control area then another eyewash must be provided that is not at a sink where disinfecting takes place. Eyewash bottles are not acceptable in a dental lab as the only eyewash facility.
c. Emergency Fire Equipment: The fire blanket should be mounted on the wall in the area where most likely to be needed, i.e. denture department, casting, etc. It should be placed in a safe location for easy access. Fire extinguishers should be mounted on the wall and if not clearly visible have a sign above them on the wall pointing to the location. The photo should provide enough view of the area for the reviewers to see that it is not blocked or access impaired in any way.
d. Signage: Photos of exit signs should be taken to show the pathway to the exit door so it can be determined if the exit is blocked or impaired in any way. Evacuation route maps should be posted and a photo provided. The information on the map varies according to the local fire marshall requirements. Photos of other signs should be submitted with enough view for the reviewers to understand their locations in the laboratory.
e. Emergency Gas Shut-Off: If there is an internal main gas shut-off, then its location should be marked with a sign. The photo should show the gas shut-off and enough view of the location to show the sign and give the reviewers an idea of its location in the laboratory. If the main gas shut-off is outside the building, then the photo can show the location but it should also be indicated on the evacuation route map so employees know its location.
f. Adequate Lighting: The photos should show the lighting in the main production area by showing a full view of this area rather than a photo of the light fixtures in place.
g. Housekeeping: The photos should show passageways and hallways throughout the laboratory together with views of work areas throughout the laboratory. Also photos of restrooms showing hand washing facilities, chairs, break areas and general work areas without dust accumulation. Photos taken during normal production times provide the best evaluation by the reviewers rather than staged work areas that are clean and not actually in use.
h. Storage For Acids: The photos should show the area where acids are stored when not in use such as supply rooms. They should be stored on lower shelves to prevent falling off shelves. If larger quantities are stored, then an acid cabinet is required. In the work area, the photo should show the containers properly marked and storage in the work area such as closed containers with absorbent material to prevent leakage. This area should also be stocked with a spill kit so a photo should be submitted showing the location and contents of the spill kit.
i. Infection Control Area: Typically this is the receiving area. The photo should show a view of this area with the sink, disinfectant, and personal protective equipment being worn by a worker. The infection control protocol is a written document that states step-by-step procedures for disinfection. A close-up photo of the protocol should be submitted. Also, the container where packing material is disposed of should be shown.
Equipment Requirements
a. Exhaust: Photos should show the ventilation to the outside for burnout, casting and boil out areas. This ventilation should be accomplished using a fan(s) sufficient to capture the fumes under the hood. The optimal distance between the top of the ovens and the hood should be no more than 18 inches. If there is more distance than 18 inches, then a chimney should be installed on top of the vent on the top of the oven to direct the fumes into the hood. When no exhaust is provided in these areas, then the lab must show results of air sampling in these areas that proves that no exhaust is needed.
b. Storage Of Cylinders: Photos should be submitted of all cylinders in the dental lab and show that they are chained or secured safely. The chain should not be around the neck of the cylinder but at a height that provides the best security. Oxygen and propane and/or acetylene cannot be stored together unless there is a barrier between the oxygen and the fuel. The barrier must provide a 30 minute fire barrier and the barrier must extend 18 inches higher than the tallest cylinder and extend away from the cylinders at least 18 inches. The alternative is to store the cylinders a minimum of 20 feet apart. The cylinders can be next to each other during operation but then must be separated when not in use. Tags should be on each cylinder indicating empty or full.
c. Suction And Shielding Devices: All grinding, polishing, and finishing equipment must be connected to dust collection devices whether central units or individual dust collection units. The photos must show the front and back views if possible so the reviewers can see the method of dust collection provided. All grinding equipment must have a guard or shield. The inoperable end of lathes must have a guard to protect the workerÃs contact with the rotating shaft, i.e. clothing, hair, etc.
d. Air Abrasion Units: The photos must show how the units are connected to dust collection and that the areas around the blasting units are free of debris. The cuffs and gloves on these units must be in good repair and not torn or missing entirely.
e. Evacuation Of Fumes: The photos must show the method of evacuation of fumes during the mixing process for acrylic. The recommended filter for these units is charcoal. Monomer fume arrestor boxes are the best means of evacuation of the fumes during the mixing process. The photo of the packing area must show how the fumes are evacuated whether in the back of the counter or an overhead hood.
f. Casting Well: The photo must show that the casting well is constructed of non-flammable materials and that no lubricants, cleaners are stored in the area of the well. Documentation can also be provided to show that workers have been trained on safety precautions for this equipment and its maintenance.
g. Air Nozzles: Air guns must be equipped with safety tips if the air pressure cannot be regulated to a maximum of 30 psi. The photos must provide enough information to verify either the safety tip or the regulator. The black rubber tips are not always a safety tip and it can be difficult from a photo to determine if there is a safety valve so when submitting a photo for this type of air gun provide written information that it is regulated to 30 psi or has a safety valve within the air gun. When a regulator is on each air pressure line, then the photo should be taken when the air gun is engaged to show the air line pressure during operation, i.e. maximum of 30 psi.
h. Personal Protective Equipment (PPE): Photos should show where and how PPE is worn throughout the lab not just the infection control area. The photos should show workers wearing the PPE and ensure that they are wearing the PPE correctly, i.e. safety eyewear, masks, gloves, gowns/laboratory coats, etc.
Hopefully the above information will assist those of you who are applying for approval as a Certified Dental Laboratory or are re-validating your application. If you have any questions on the above, please refer also to the written information for CDL applications on the NBC Web site (www.nbccert.org), but also feel free to contact Safelink for further clarification.
