Do Dental Offices Need to Have Emergency Eyewash Stations?

This is one of the questions asked by several dental offices, even though the risks of an eye injury occurring in a dental office are quite high. Dentists are obliged to exercise due diligence in taking every reasonable measure to protect their workers and patients.

Dental offices in Ontario, for example, are required to follow health and safety legislation, including the Occupational Health and Safety Act and Regulations. There are many regulations that could apply to your dental office. For instance:

— WHMIS Reg. 860;
— X-ray Safety Reg. 861;
— Industrial Establishments Regulation (IER) Reg. 851;
— Designated Substances Reg. 490/09 for Lead; and
— Control of Exposure to Biological or Chemical Agents Reg. 833 for Nitrous Oxide Anesthetic Gases etc.

One would think that the Health Care and Residential Facilities Regulation (HCRFR) 67/93 would cover dental offices, but they do not. They must follow IER 851. If a hazard exists that is not dealt with in the IER, but it is dealt with in the HCRFR or another regulation, you may still need to comply due to the general duty clause in OHSA, e.g., that the employer/supervisor must take every precaution reasonable in the circumstances to protect a worker.

Applicable Legislation for Emergency Eyewash Stations in Ontario

Occupational Health and Safety Act (OHSA)

Regulations
25(2)(h), 27(2)(d) General Duty Clause (Due Diligence) — Take every precaution reasonable in the circumstances for the protection of a worker.
Here is an applied example of due diligence: If there is a risk of eye exposure to biological (blood or body fluids) or chemical hazards, it would be due diligence for the employer/supervisor to provide an eyewash station. It would also be due diligence to provide eye protection to the worker, in addition to ensuring there is training, education, policies and procedures. There should also be documentation of these, including signatures and signoffs.

IER 851
124. Where a worker is exposed to a potential hazard of injury to the eye due to contact with a biological or chemical substance, an eyewash fountain shall be provided. R.R.O. 1990, Reg. 851, s. 124.

WHMIS Ont. Reg. 860
Check your MSDS to see if an eyewash station is required as a first-aid measure for the WHMIS products that are used in the dental practice.

The Ontario Ministry of Labour follows the American National Safety Institute (ANSI) Standard Z358.1-2014 for emergency eyewash and showers as best practice. The Canadian Centre for Occupational Health and Safety outlines eyewash-station requirements based on the ANSI Standard. Its website is a very good resource for other oh&s topics: http://www.ccohs.ca/oshanswers/safety_haz/emer_showers.html

It is also helpful to visit the link to the dental page of the Public Services Health and Safety Association, which addresses dental practices.

Additional things to consider when installing an eyewash station:

— The eyewash station should be located in a central area where the injured worker could reach it within ten seconds. Keep in mind that the injured person would not be able to see, so easy access is critical;
— The eyewash station should have a thermo-regulator to ensure that the water temperature is tepid, not too cold or too hot;
— The eyewash station should have the ability to continuously wash both eyes for 15 minutes. That is why portable eyewash stations are not suitable for that purpose;
— There must be a sign posted above the eyewash station to indicate its location clearly; and
— All staff should be trained on how to use the eyewash station.

The health and safety of all workers is serious business. Dentists are responsible for having a program in place to prevent injuries to your workers and patients. If a critical injury occurs in the workplace, dentists can be subjected to very heavy fines if they cannot prove that they exercised due diligence and made every reasonable effort to protect their employees. The fines vary in range and can be thousands of dollars per occurrence.

Having a health and safety program in place, including monthly inspections, signing off on the policies and reviewing procedures, will not only protect the workers, but also protect the dentist.

Sandie Baillargeon is the solution designer, owner and practice management adviser of Dental Office Consulting Services in Burlington, Ontario. A leading authority on how to increase the effectiveness of dental business systems, Sandie is the author of two textbooks, Dental Office Administration and The Canadian Dental Office Administrator.