Compliance Corner

Pressure Vessel (a division of OSHA) and Santa Clara County Department of Environmental Health Hazardous Materials Compliance Division have recently begun inspecting dental offices. In addition, many of you have recently received a letter from Santa Clara County Department of Environmental Health Hazardous Materials Compliance Division regarding the discovery of untreated medical waste in landfills. As a result, they have increased vigilance and are investigating cases of illegal disposal.

It is therefore increasingly important that you understand the regulations and the consequences for violations. This is intended to alert you to the types of inspections you might expect, and what the inspectors will be looking for.

1. Pressure Vessel is a division of OSHA, but is separate from OSHA Regulatory Enforcement. They are inspecting compressors; the inspection will take about 20-30 minutes. If you pass the inspection, you will receive your Pressure Vessel Registration and an invoice for about $250 within a few weeks; the registration is good for five (5) years. If you do not pass the inspection you must correct the problem and then contact Pressure Vessel to inform them when the problem has been corrected. Once the problem is resolved they will release the Pressure Vessel Registration. If you share a compressor with other dental offices in your building, you should contact your landlord as you are responsible to have at least a copy of the Pressure Vessel Registration in your office.

2. Santa Clara County Department of Environmental Health Hazardous Materials Compliance Division has two groups that may inspect you. One deals with Hazardous Waste and the other with Medical Waste.
   1. Hazardous Waste includes fixer, developer, lead foil and scrap amalgam. The inspector will want to see your current Hazardous Waste Generator permit, and then they will want to see your manifest or tracking documents (who, what, and where your waste is going). They will ask to see your darkroom and your inspection checklists, so make sure you are doing your quarterly inspections.
   2. Medical Waste includes extracted teeth, Sharps, and gauze or cotton rolls saturated with blood or saliva (saturated means that they would release blood or saliva if compressed). If you are using a Sharps mail-back system, be sure to complete the tracking document and keep it in your Medical/Hazardous Waste Notebook. The inspector will want to see your Medical Waste Generator Permit, and they will want to know where you are sending the filled Sharps containers. As for the extracted teeth or gauze or cotton rolls saturated with blood or saliva, I have given you a Medical Waste Container, autoclavable red bags and complete instructions for treating medical waste on-site. The most important thing the inspector will want to see is your log book, to make sure that you are not treating more than 20 lbs. a month.