We like to provide clients all the materials they need to prepare for the next calendar year. We usually try to get it to them before Christmas, so it’s a sort of Christmas present. One of the things we include in this packet is a blank master chemical list. We’ve been getting a lot of questions about this list, as well as establishing a code of conduct. Listen to this episode to learn about both of them!
Outline of This Episode
- [0:40] A compliance Christmas present
- [5:11] Nail down your code of conduct
- [7:29] Maintain a master chemical list
- [9:37] The lowdown on safety data sheets
- [11:10] Check out our live training!
Nail down your code of conduct
If you participate with Medicare, Medicaid, Tricare, or other government programs, you need to have a written compliance plan that includes the seven elements of compliance. It’s a supplemental document to your office policies and procedures (employee handbook, SOPs, OSHA policies, HIPAA policies, compliance policies, billing protocols, etc.).
It’s impossible to have written procedures for every scenario that may occur in the dental practice. So this supplement establishes a decision-making framework for your staff in the absence of a policy or procedure. They are principles to follow to reason through any situation. In short, it’s a behavioral guidance tool.
To remain compliant, this code of conduct needs to be reviewed by your staff at least annually. It should be part of the new-hire process and repeated with everyone in the practice—doctors, clinical staff, and administrative staff. You have to read it, discuss it, and sign off on it.
Whether a signed form goes in each employee record or a compliance manual, you just need to be consistent. You have to be able to prove that you have a reasonably effective compliance program in place.
How to maintain a master chemical list
Another thing we include in the update packet we send is a blank master chemical list. Why? Because you need to know what chemicals are being used in your practice. They need to be accessible in the event of a power failure. If you prefer to keep things online, make sure you can access it on your cellphone or have it transferred to a thumb drive for easy access. If you can meet that threshold, you should be good. You can delegate this to a staff member or OSHA coordinator, as long as someone knows where it is.
Safety data sheets
We've been getting questions about where to store safety data sheets. Does it have to be printed? Can it be online? The short answer is that it can be online, but needs to be maintained in the office as well. It should be a table of contents for your practice.
In 2012, we migrated to a DHS system in which they had standardized the format for safety data sheets. Before this, they had been known as material safety data sheets (MSDS). The formatting is now consistent. If you have printed MSDS sheets, it’s time to upgrade them to the proper format.