The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
#105 Is Your Office Prepared for An Emergency Evacuation?
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In recent years we have seen increases in severe weather outbreaks and other types of emergencies that may require a dental facility to be evacuated. This episode will explore OSHA's requirements and important facts that dental teams should consider when developing or updating their safety plans.
Resources:
- Elements Necessary for a Violation of the OSHA General Duty Clause https://bit.ly/3pwooic
- OSHA eTool for Evacuation Plans and Procedures https://www.osha.gov/etools/evacuation-plans-procedures
- OSHA How to Plan for Workplace Emergencies and Evacuations https://www.osha.gov/sites/default/files/publications/osha3088.pdf
- OSHA Fact Sheet on Emergency Exit Routes https://www.osha.gov/sites/default/files/publications/emergency-exit-routes-factsheet.pdf
Welcome. I'm Leslie Cannum. I'm Mary Gavoni.
SPEAKER_01I'm Linda Harvey. I'm Olivia Juan. And together we are the Compliance Divas.
SPEAKER_02Welcome to the Compliance Divas Podcast. I'm Mary Gavoni and I'll be the moderator for this episode. The compliance divas bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. You can subscribe to the Compliance Divas podcast through your favorite podcast channel or on our website, thecompliancedeivas.com. The resources we mentioned during our podcast can be found on the ComplianceDivas.com website, and you may always submit questions to support at thecompliancedivas.com via email. A recent podcast guest, Henry Serrano, reminded us of the importance of emergency action plans. And although the focus on that episode was oxygen tanks and what to do, in this episode, we're going to explore and discuss OSHA's regulations for emergency action plans under the general workplace safety standard. This is part one of a two-part episode. Today we'll talk about evacuation plans for the office. And part two, we'll discuss emergency action plans for active shooter and other outside threats andor workplace violence. So, Leslie, will you please start us off and clarify for our listeners what is an employer and an employee's responsibility under the general duty clause from OSHA?
SPEAKER_00Well, Mary, the general duty clause is something that many dental offices are not aware of in and of itself. They think of the bloodborne pathogen standard and the hazard communication standard and other attending regulations, but the general duty clause, which is actually section 5A1 of the Occupational Safety and Health Act, requires that each employer furnish to each of its employees a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm. Now, in a dental office, we do have some materials that we work with that are considered to be hazardous to health. And certainly there are some physical injuries that we could suffer, a fire if we work with items that are flammable or sharps injuries with sharp contaminated devices. And the general duty clause actually, the provisions can be used by OSHA where there's no standard that applies to the hazard, like blood-borne pathogen or hazard communication. And the employer's own employees are exposed to an alleged hazard. Each of the 26 states and two territories who operate OSHA-approved workplace safety and health programs have adopted this or an equally effective provision. So what this really boils down to, Mary, is that these are elements that are necessary for OSHA to prove a general duty clause violation. Many times dental practices say, you know, well, you know, how would I be in violation? Well, here's exactly how. First, the employer failed to keep the workplace free of a hazard to which its employees could be exposed. Secondly, the hazard was recognized by the employer. That means the employer can't say, I didn't know that that was a hazard. And third, the hazard was causing or was likely to cause death or serious physical harm or which would be considered to be a very serious violation. And then fourth, there was a feasible and useful method for correcting this hazard. So, Mary, there's where you have what employers are responsible for under the general duty clause. And of course, employees are required to follow the employer's safety standards that are under the general duty clause.
SPEAKER_02Thank you, Leslie. That is a very good explanation. And I agree with you that there are many dental practices that don't understand the implications or the overreaching power of that general duty clause. So our Diva Linda Harvey couldn't be with us today, but she gave us some really great information about emergency evacuation plans. One of the questions we get a lot is do the emergency evacuation plans need to be in writing? And OSHA is a little bit wishy-washy on this, if you will, in that if you have 11 or more employees in your practice, yes, you have to have it in writing. If you have less than 11 employees, you do not. But it seems to make sense to me at least that you, if you're going to go to the to the trouble of creating an emergency action plan or an emergency evacuation plan, that you do put it in writing. And the the thing that a lot of people have questions about as well is what kind of workplace emergencies are we talking about? So according to OSHA, a workplace emergency is an unforeseen situation that threatens employees, customers, or patients for us, the public, disrupts or shuts down your operations, or causes physical or environmental damage. Emergencies may be natural or man-made and may include floods, hurricanes, tornadoes, fires, toxic gas releases, probably not likely to happen in a dental practice, unless somebody spills the form of creosol, chemical spills, same category, radiological accidents, explosions, civil disturbances, and workplace violence resulting in bodily harm and trauma. And that's what we've seen a lot of recently in workplaces. So an emergency evacuation plan, according to OSHA, covers designated actions that employers and employees must take to ensure employees' safety from fire and other emergencies. So there's great resources on how to create these emergency evacuation plans. And we will put those in the resources in the show notes and on our website. There is even an e-tool that you can go to for OSHA that actually creates the plan. You check the boxes in this e-tool and it will print off your emergency evacuation plan for you. So it makes it really, really easy to do. So, Olivia, a critical part of emergency evacuation is what about exits? And OSHA has some very specific information about requirements for exit doors and signs. Would you be willing to share that with us?
SPEAKER_01Sure, Mary. And we'll have this information for our listeners because there's great OSHA fact sheets that they can review that condenses the information down. But if ever there is an emergency and you have to evacuate quickly, then we need to make sure that the exit route is clear and conforms to OSHA's requirements. So for example, the discharge must lead directly outside or to a street, walkway, public way, open space. So that's an important piece that it's not simply an exit leading to an exit. What are those main exit routes to take us outside of the building? And also a good point, Mary, is that the exit route doors must be unlocked from the inside. I've actually seen some dental practices cited on this area of compliance where it was locked from the inside. Obviously, we won't we're concerned about someone entering unauthorized, but you know, a newer building would have a crash bar. So even though it's locked from the outside, you can still exit if you had to. So that's something I would like for smaller practices to be mindful of. You can't be trapped inside. And many years ago, I used to use an example of some factory workers where there was an emergency evacuation to take place because of a fire and there was smoke in the building, and they found those workers dead behind the door because they were locked inside the building. So this is very meaningful, serious information. Additionally, Mary, it should the doors itself should be side hinged exit doors to connect the rooms to the exit routes. So they have to swing in the direction of exit travel if the room is to be occupied more than 50 people, or if it's a high-hazard area. And the exit access must be at least 28 inches wide at all points. And then another point that I thought was interesting is that if it's an outdoor exit route, if it how would I describe this? I have to reflect back on an experience I had where a dental office was located on a second level and one of the fire exits led outside, and it had a landing and stairs, but there was no guardrails. So if you were like rushing out of the building, here's this platform and stairs, but no guardrails. So that is actually in OSHA's fact sheet that there must be guardrails to protect unenclosed sides if a fall hazard exists. So some key takeaways in addition to that is to keep the exit route door free of decorations or signs that can obscure the visibility of the exit route doors, uh, even curtains or anything around the exit signs, and then post signs along the exit access indicating the direction of travel. So it's just like when we're on site, we're working with clients, they might know the exit route. But would someone in your building know that? Would your patients or whoever's visiting in the building know how to follow that path? So we should mark the doors or passageways along an exit access that could be mistaken for an exit or you know, put the words on the outside of the door, not an exit. Now I know people don't like ugly signage, but we don't want people going into a closet and wasting valuable seconds that they could have gone to the correct door. And then the exit signs need to be plainly legible letters. So I think these are all good points, Mary, for people to be mindful of. And as I mentioned, it has been the result of citations.
SPEAKER_02Absolutely. Thank you, Olivia. And that was a great point about the guardrails. I can think of a client office that was in that kind of a situation, and it was kind of scary. The office was built up on a hill, and so you went out on the first floor level, but the back door, the back exit door was out to a platform with no railings around it. So that could be an issue. Another thing that you may want to consider is wherever your practice is, do you need signs that are in English and, for example, Spanish? Because you have a lot of um folks for whom English may not be their first language. And your building code in your city or town will tell you whether or not those exit signs need to be lit and backed up with batteries. That's usually a um sort of a jurisdictional thing. And I know that there are some states, depending on the square footage of the building, where they even require lit signs to be at floor level so that if someone had to crawl out underneath the smoke, which rises up, um, they could still see hopefully the lit exit sign. So always check with your local fire department or your local building inspector to make sure that you're meeting those particular requirements. So evacuation plans, I think we all would agree, should be practiced. And, you know, schools have fire drills, everyone, you know, practices what to do because when something happens, a lot of times people will panic. So just like you would practice or prepare to respond to a medical emergency, what if there was a fire in the practice? What would you do? Would you use the fire extinguisher? Do you know where the fire extinguisher is? Has it been inspected recently? Um, but the other issue is, and of course, we're experiencing so many severe weather issues lately. How does your practice or how would your practice know if there was a severe weather alert? So it may come to someone's cell phone, maybe they subscribe to the local TV station's weather alert network, or like the weather channel, or is there an alert network that comes from, say, your county or your city or town? So you need to know if you need to take cover. And the importance of this, of course, is to protect the team members and also to protect the patients because you're responsible for the safety of those patients while they're there in your practice as well. So, Divas, do you have anything else that you would like to um share with us as we wrap up this episode? Leslie.
SPEAKER_00I was at a dental office where they would store their mop and their bucket outside of their back door. And that mop could have fallen across and made it difficult for the door to be opened and maybe even trap someone inside. So I would encourage our listeners to take a look around, not only for obstructions in your exit route, but also make sure there's nothing outside the door that could be an obstruction. And I love the idea, Mary, of fire drills. I think that we don't take those seriously enough. And we should perhaps encourage our listeners to set up something, maybe uh at a time where there's not patients in the office, perhaps uh just before the lunch break or at the morning huddle, where you stage a fire drill. And you can even do it with flashcards. I had one very smart person from a joint commission's audit uh perspective tell me that she created some little laminated flashcards and she had a picture of flames and she put it on the staff lounge microwave and said, okay, folks, you have a fire in your microwave. What are your first steps? So if you're not going to have the written plans because you have a small practice, let's actually get the muscle memory in place as to what we're gonna do, how we're gonna evacuate, and make sure that everybody understands that what is the closest door for me to evacuate? And uh everybody has a role in assisting patients out of the practice. Did someone check the restroom? Did they check all of those areas that might have a closed door, like a closet? Because we, of course, OSHA cares about us as employees, but we care about our patients. So I would hope that we would have a little opportunity to practice what we are talking about when it comes to an emergency action plan, and maybe even include in your practice somewhere an egress map that you can very easily do with a pencil and a ruler to uh just show the rooms of your practice and the exit route. You might even include on that map where a fire extinguisher is located, perhaps have a legend for that, a legend for where the eyewash station is. So you have an all-inclusive emergency action map showing those exit routes so that not only the team members are informed, but uh anyone that visits the office, whether it's a repair person or whether it's a patient, that they would be able to easily see where the emergency exits are and where the emergency equipment is. Excellent, Leslie. Olivia?
SPEAKER_01And and just to mention, I've seen in several offices where the package delivery people will set boxes right in the way of a main exit. And I've taken photos to put into my report that even if those boxes were there just a few hours, it's still blocking that emergency exit and it is in violation. So need to have someone assigned if packages are brought in, they need to be placed in an area that's not obstructing that main exit and fire route.
SPEAKER_02That is so important about those um obstructed exits. I was called into um a practice a couple of years ago where the employees really fled with their doctor to um have me come in and reinforce their concerns because there were boxes of just stuff and used equipment and in the in the corridors and in the area where that led to the exit doors, and patients were complaining that they had to step around things. And you would think it would sort of be a common sense thing, but sometimes you can't see the forest for the trees. And so we made sure that they had a cleaning day to get all those things out to unobstruct the exit. Um, and employees were just concerned for their welfare and the welfare of their patients. So hopefully, this brings our listeners some good information about the importance of pre-planning. Again, just like we would plan and practice for a medical emergency, it's not that likely that you would have a fire or some reason to evacuate your office, but you certainly could be in the path of some threatening weather. So in the resources again, you will see the OSHA e tool that you can go to and it will help you to design your own emergency evacuation plan, which you should then post and make sure everyone knows. So we thank you for joining us. And keep in mind that the compliance divas bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Resources will be in the show notes for the episode and also on the compliance divas website, thecompliance divas.com. And if you have any questions, please email them to us at support at the compliance divas.com. Thanks for listening.