11th Covid-19 Newsletter – “New OSHA and BOD Emerg Rules”
 Staff of MSDS wish you to Stay Safe, De-Stress and Stay Active! Linda, Anee, Saba, Ifra, Chelsie and Patrick (no photo)      MSDS views all of our Dental Clients as Healthcare Providers! We Thank all of you for your Outstanding work and all that you do!! 11th Covid-19 Newsletter – “New OSHA and BOD Emerg Rules”Scroll down after reading to see some sample invoices to help understand the potential process!  Major glove factories close after thousands of workers test positive for COVID-19 The largest rubber glove manufacturer in the world said this week that orders would be delayed by weeks and some of its factories would be shut down after thousands of its workers tested positive for COVID-19. “To minimise the impact on our customers, we are allocating sales orders to unaffected factories and rescheduling deliveries where possible,” Top Glove Corp of Malaysia said in a statement. According to the company, deliveries could be delayed by up to four weeks and new orders could take even longer. As Reuters notes in its report, shares of the company have shot up in value this year due to the high demand for personal protective equipment. The company commands a quarter of the global latex glove market. Top Glove operates 47 factories across Asia, 36 of which produce gloves. It previously had to shut down 16 factories and reduce the capacity of 12 others. In its statement, the company did not say how many factories would be affected by the new order. Top Glove’s production capacity will likely be reduced to 50 percent of what it normally produces, according to Malaysian Industrial Development Finance research analyst Ng Bei Shan. Malaysia produces nearly two-thirds of all the rubber gloves in the world, according to the Malaysian Rubber Glove Manufacturers Association. The other two major glove manufacturers, Hartalega Holdings and Supermax Corp, are not believed to have the capacity to make up for the expected delay caused by Top Glove’s shutdowns. Klang, a region just west of Malaysian capital Kuala Lumpur where Top Glove’s factories and dormitories are located, has seen a surge of new cases according to the country’s health ministry. In order to fight this cluster, the largest Malaysia has seen so far, the country erected barbed wire in front of the workers’ hostels and set up checkpoints with police and soldiers. Link on Vinyl Gloves: https://mms.mckesson.com/catalog?node=37475 OSHA is Not Playing Around! Section 1. I cannot stress how important this is. I really doubt OSHA will negotiate the citation for anything that has to do with Covid. And we know the Board of Dentistry will not. MSDS has the supplies to get your staff Initially Fit Tested. This includes A. Fit Testing Hood https://www.msdssafety.com/product/fit-testing-hood-59-ea B. Fit Testing Bulb Nebulizer https://www.msdssafety.com/product/fit-testing-bulb%E2%80%A6izer-69-ea-m9934/ C. Saccharine to make Threshold (.83%) & Fit Test Solution. (83%) https://www.msdssafety.com/product/fit-testing-saccharine-powder-23-30ml-m3335/ D. N95’s https://www.msdssafety.com/product/n-95-respirator-mask-m9920/ E. FIT TESTING N95’s for your Personalized Respiratory Protection Program for the Dental Healthcare Provider – #M9918 Price $50.00 each staff. https://www.msdssafety.com/product/personalized-respiratory-protection-program-for-the-dental-healthcare-provider-m9918/ E. Personal Respiratory Protection Manual for the Dental Healthcare Provider – #9926 Price: $499.00. https://www.msdssafety.com/product/personalized-respiratory-protection-program-manual-for-the-dental-healthcare-provider-m9926/ F. Occupational Health Physician Clearance & Secure Backup https://www.msdssafety.com/product/secure-backup-of-the-medical-questionnaires-and-occupational-clearance-m9922/ G. UV Lamp (See Section 3) https://www.msdssafety.com/product/ultravoilet-light-uv-light-499-ea-1-m9923/ MSDS only has 8 cases of N95’s left, but enough to get all of my clients Initially Fit Tested and will track down more if needed. I know all of the dental reps also have them available. They must be NIOSH Approved. We are currently selling them for $4.50 each. I have had a lot of Clients state they were told – level 3 masks with a full face shield if there is no N95’s. This is not going to fly anymore – as Dental Suppliers have NIOSH approved respirators available as does MSDS. Below is the Frequently Cited OSHA Standards in Screenshot form, Related to COVID-19 Inspections. I have added a link to the location of the screenshot so you can clearly see that we are not making this up. MSDS has answered all of these questions in Section 2.  https://www.osha.gov/SLTC/covid-19/covid-citations-lessons.pdf Answers to the OSHA Inspections Most Frequently Cited: Section 2. 1. Medical Evaluation: MSDS has partnered with a Compliance Company for Occupational Health. All Confidential Medical Evaluations must be reviewed by an Occupational Healthcare Provider. The dentists is never to review this Medical Evaluation. How does the Confidential Medical Clearance Evaluation Questionnaire work? MSDS sets your office up an account. Then all clinical staff who will work with aerosols will complete the questionnaire online (still very confidential) through their private email address. The Occupational Healthcare Physician must approve all staff prior to fit testing. If a staff doesn’t get approved right away (MSDS will receive a certificate of approval) they will send the staff a private email with additional questions or concerns. If that is not enough to get the staff approved, they will actually talk to the staff directly. When all three are still a no, the Occupational Health Physician will guide them into what they need to do next. You may not fit test till evaluation is completed and you receive a certificate to Fit Test. I haven’t had any staff fail completely, however, this way everything is very strict and straightforward and safe. The three S’s on Safety! 2. Initial Fit Testing: If the office wants to be trained by MSDS to complete the Fit Testing, we will only charge 3 staff. Linda will explain how to do each step. Then she will have the doctor complete with Linda’s help and the third one the doctor will complete. Rule of 3’s! 3. Assess the workplace for Covid-19 Hazards. This is why it so very important to have a Covid Binders. With picture of A. Front office B. Waiting Room C. Operatory pic with staff wearing PPE during zero Aerosols D. Operatory pic with staff and doctor wearing PPE during Aerosol treatment. E. Sterilization Changes (a rogue consultant who claimed to be an OSHA consultant has been telling offices to wear double gloves. This is not allowed. You must always look at Universal Precautions with Bloodborne Pathogens. OSHA would not ask you to go against Federal Guidelines. F.Screening for Patients. Pictures or a Letter stating the policy if the screening is in the Dental Program. G.Screening for Staff. I recommend to do a screening before start of the day and after lunch. Get in the habit now. If you have staff or patients test positive, you may have to double screen staff. So just do it now. H.How you are storing your N95’s? Brown Paper Bag? Are you using our UV Lamp and then the staff takes it directly from there and switches it with the one they are currently wearing? Read below about our 360 Sunshine UV Lamp. No Ozone! No Mercury! And 60 seconds to Covid death! 4. Establish, Implement and Update a RPP Manual: MSDS will write your Personalized Respiratory Protection Manual. If MSDS takes care of this Manual for you, we will cover any and all additional write ups, or inserts and changes in the future written by OSHA. You will only be responsible if you want a more specific write up for the manual. 5. PPE correct Size, Type, Duration: This includes your A. N95’s, KN95’s, or Level 3 or lower Masks B. Cloth or Disposable Gowns C. Gloves D. Taking off all PPE 6. Train and Retrain Workers to use Respirators and PPE. This includes changes that make the previous training obsolete. A. Weight Gain and Loss of 10 or more lbs B. Medical Changes that may affect the Fit Test or PPE. **Remember you can always ask staff and patients (example) who say they can’t wear a Respirator, Mask, Face Shield, Isolation Gowns, etc, to secure a doctors note. The letter will not state the reason, just that they cannot wear, so you have documentation. C.Federal Guidelines Change 7. Store Respirators and other PPE Properly. This is no different then OSHA-BBP barrier from clean/dirty . The masks, if placed in a brown paper bag with employees name on the bag, needs to go in an area where there is no cross contamination but also that is not sanitary as the bags are not clean. See UV Lamp below. 8. Fatality from a Work Related Incident. This is only for staff members, not patients. MSDS will be there for you. 9. Required Records: A. Form 301 due to Incident Exposure. Please Fill this out if you have a staff member test Positive with Covid. You will still have to call the Health Department if you have 3 staff test positive within 14 days of each other. B. Fatalities at work must be called into OSHA within 8 hours. C. MSDS’s Occupational Healthcare Provider will hold the Confidential Medical Clearance Questionnaire and the Occupational Physician review for 30 years past the last employee’s day with the office. – All Confidential Medical Evaluations must be saved by the Occupational Healthcare Provider for 30 years past the last day of the staff’s employment. Please understand that the backup of the Confidential Medical Evaluation is only a few dollars. The rest of the fee is for the Occupational Healthcare Provider to review and potentially email and speak to the staff. 10.MSDS will remain your source with the Occupational Healthcare Provider’s online Confidential Medical Evaluation. 11.Preliminary Invoice MSDS will be happy to complete a preliminary invoice. We also know how financially tight you are during this time. If you need to spread this out over 3 months, we are happy to help. We keep our prices down because we don’t have a bookkeeper sending out statements. So if you need this service, there is zero extra fee, however, you must pay with a credit card. Guidance for Asymptomatic HCP Who Were Exposed to Individuals With Confirmed COVID-19 Section 3.  https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-risk-assesment-hcp.html ** Scroll down to Guidance for Asymptomatic HCP Who Were Exposed to Individuals with Confirmed COVID-19Higher-risk exposures generally involve exposure of HCP’s eyes, nose, or mouth to material potentially containing SARS-CoV-2, particularly if these HCP were present in the room for an aerosol-generating procedure. Add the Form in Screenshot – and add the Link to the bottom of the page. (It’s on the desktop of the iMac Tri. Then Type the below information. ** **: This is Linda Speaking and not from the document. HCP=healthcare personnelData are insufficient to precisely define the duration of time that constitutes a prolonged exposure. Until more is known about transmission risks, it is reasonable to consider exposure of 15 minutes or more as prolonged. ** This is considered 15 min total even if you have seen them for only 5 minutes 3x’s. ** However, any duration should be considered prolonged if the exposure occurred during the performance of an aerosol-generating procedure.Data are limited to the definition of close contact. For this guidance it is defined as: a) being within 6 feet of a person with confirmed COVID-19 or b) having unprotected direct contact with infectious secretions or excretions of the person with confirmed COVID-19. ** If you are speaking, talking, singing or laughing – think 10 feet** Determining the time period when the patient, visitor, or HCP with confirmed COVID-19 could have been infectious:For individuals with confirmed COVID-19 who developed symptoms, consider the exposure window to be 2 days before symptom onset through the time period when the individual meets the criteria for discontinuation of transmission-based Precautions.For individuals with confirmed COVID-19 who never developed symptoms, determining the infectious period can be challenging. In these situations, collecting information about when the asymptomatic individual with COVID-19 may have been exposed could help inform the period when they were infectious.In general, individuals with COVID-19 should be considered potentially infectious beginning 2 days after their exposure until they meet the criteria for discontinuation of transmission-based Precautions.If the date of exposure cannot be determined, although the infectious period could be longer, it is reasonable to use a starting point of 2 days prior to the positive test through the time period when the individual meets criteria for discontinuation of Transmission-Based Precautions for contact tracing.While respirators confer a higher level of protection than facemasks and are recommended when caring for patients with COVID-19, facemasks still confer some level of protection to HCP, which was factored into this risk assessment. ** This means if you choose to wear a level 3 mask during an Aerosol Generating Procedure, you will have to complete the Work Restrictions. Which means you will have to exclude from work for 14 days after last exposure. I would not take that risk ** – Cloth face coverings are not considered PPE because their capability to protect HCP is unknown.If staffing shortages occur, it might not be possible to exclude exposed HCP from work. For additional information and considerations refer to strategies to Mitigating HCP staffing shortages. ** We do not have a shortage if you can get them. Dental Suppliers and Myself have N95’s. ***For the purpose of this guidance, fever is defined as subjective fever (feeling feverish) or a measured temperature of 100.0oF (37.8oC) or higher. Note that fever may be intermittent or may not be present in some people, such as those who are elderly, immunocompromised, or taking certain fever-reducing medications (e.g., nonsteroidal anti-inflammatory drugs [NSAIDS]). ** Here is an additional link to OSHA’s Risk Pyramid. Please understand that just because we are Very High; OSHA always looks at Risk without the use of PPE. So you maybe very high, but if your PPE is on target, and you are following Procedures, you are as safe as anyone seeing a Covid-19 patient and we do not see Covid-19 patients. That is why we screen. If one slips through the cracks, then you follow the above protocol.** https://www.osha.gov/Publications/OSHA3993.pdf UV Lamp Information and Directions Section 4. Researchers from the HRHS say the outside and inside of the N95 were decontaminated in a prototype phototherapy unit that dispenses a UV-C dosing level high enough to effectively kill the virus in less than two minutes (60 seconds on each side) while still preserving the Respirators breathability, fit and overall integrity. Great for Operatories, Waiting Rooms, Private Office Sterilization Area. Will tackle up to 800 sq. ft. Timer to 4 hours. If you are within 15 feet, the motion detector will shut off the lamp. 360 Sunshine UVC Lamp are an Amazing addition to your office and a true must have in our opinion. If you are a Healthcare Provider or not – Please read the below disclaimer: What are the risks of using a UV-C lamp? • Direct exposure of skin and eyes to UVC radiation from some UVC lamps may cause painful eye injury and burn-like skin reactions. Our Sunshine Lamp has a Motion Detector. If you, or an animal are within 15 feet – the UVC Lamp will shut off. I will turn on when there is no motion within 15 feet. (talk to your aquarium specialist on how to protect your fish). Purchaser assumes all risks if they block the Motion Detector. It is always advised to wear a 100% UV-C safety glasses when you have the potential to be exposed with UVC. **Never look directly at a UVC lamp source, even briefly. If you have experienced an injury associated with using a UVC lamp, we encourage you to report it to the FDA. Think Welder’s Burn. • Some UVC lamps generate ozone. Ozone inhalation can be irritating to the airway. Our Sunshine UV-C Lamp has …. Zero, Nada, No Ozone! • Some UVC lamps contain mercury. Because mercury is toxic even in small amounts, extreme caution is needed in cleaning a lamp that has broken and in disposing of the lamp. Our Sunshine UVC Lamp has No Mercury. It’s the top of the line, with LED’s. Only a few 360 Sunshine UVC Lamp on hand. Two weeks to get yours to your doorstep. Once we are out of them in the warehouse, will be 30 days to get additional lamps until restocking has occurred. Great for Operatories, Waiting Rooms, Private Offices, Sterilization, Lab or Kitchen. Up to 800 sq. ft. Timer to 4 hours. If you are within 15 feet, the motion detector will shut off the lamp. Once you are past 15 feet, 360 Sunshine UVC Lamp, the light will turn on in 3 seconds to finish up the time you set the Lamp. We do not ship outside of the United States. However, if you want me to check on Pricing to ship outside of US, know it will cost at least $50.00 plus dollars. I will not be responsible for delays in shipping. Warranty for 1 year. This will be handled directly to the manufacturer. If you are wanting more than one 360 Sunshine UVC Lamp, please contact us through Ebay and request a quote. 20% of all profits will go towards our 501c3 (CannonRidge, or CRTRC. We help Anxiety, Abuse, and PTSD through horses). See Attached Pictures of The 360 Sunshine UVC Lamp. UV-C Range is from 254nm – 280nm A new study from Henry Ford Health Systems – Look on on Google.           Here are the sample Invoices:   Winner of the week Winner of the week Instead of the “Question of the week”; MSDS will be adding: *Questions and concerns from our clients *Literature of Potential scam/spam *Updates from the Board of Dentistry *New Regulations from Federal or State *And Grammar/Spelling Errors.  Weekly winners will receive a $10.00 gift card to Starbucks! Names are drawn by the app below. https://miniwebtool.com/random-name-picker/  Organizing your computer for MSDS:Make a folder on your desktop named MSDS.Double click the folder.Create Folders for each category. OSHA-BBP, OSHA Safety Classes, HIPAA, Medical Emergency, BLS-CPR, etc.In each folder, for example, HIPAA:You’ll have the Business Associate Agreement, Patient Consent Form, Office’s Privacy Practice, etc. We love our ClientsMSDS911ADDITIONAL SERVICES OSHA-BBP Exposure Control Plan.Mandatory by Federal OSHA-BBPRequired to be PersonalizedReviewed Annually by all office staff involved in OPIM. (Other Potentially Infectious Materials)This manual is also called: The OSHA manual, The Exposure Control Plan or The Bloodborne Pathogen manual. If you want MSDS to help you with your Personalized manual. The cost for non clients is $450.00. Cost for Clients is $250.00 this gives you not only a personalized manual in binder form, but also in PDF which is the format the Inspectors will want you to have. Best to know that we will not have you answer incorrectly vs. you writing your own manual and the manual is incorrect. MSDS can boast that our manual has never been given anything less than an A+ from an OSHA inspector. |
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