OSHA’s Respiratory Protection Standard & Dental Mercury

This video demonstrates that a brand new jar of pre-encapsulated amalgam dental fillings release high levels of mercury vapor. Additionally, a newly mixed (triturated) amalgam filling was also shown to release quantities of mercury vapor vastly in excess of established safety limits by the EPA and ATSDR (a subset of the CDC). Video from the International Academy of Oral Medicine & Toxicology (IAOMT)

Occupational exposure to dental mercury often exceeds OSHA safety standards thus requiring respiratory protection. At Dental Safety Solutions, we are proud of all those dentists who take steps to protect their staff from mercury exposures by providing them respiratory protection during amalgam removal. But did you know that use of respirators only addresses part of your regulatory obligations?  Education is an important part of what we do here at DSS.  Our mission is to help you understand which OSHA standards apply to dental employers who place or remove mercury amalgam dental fillings and to simplify compliance by offering training and safety packages that ensure you and your staff are well protected and compliant.

“OSHA’s Respiratory Protection Standard 29 CFR 1910.134 applies to any employee who wears a respirator.”

Respiratory Protection Guidelines

When discussing occupational safety with dentists, it is inevitable that OSHA requirements are brought up. Quite often dentists are unaware of requirements such as the need for respiratory protection in workplaces where employees are exposed to hazardous airborne contaminants above safety standards. Unfortunately, the most common response is “But I’m a dentist. Respiratory protection isn’t needed… is it?”

While that answer depends upon a number of factors, one thing is for certain, OSHA requires all workplaces with known hazards to inform the employees of the exposure, provide personal protection but first to perform a hazard assessment that will determine exactly what kinds of safety implementation is necessary. That is where Dental Safety Solutions can help achieve full compliance. This not only protects you and your employees from most workplace hazards but it may also defend your business from lawsuits.

1910.132(d)(1)
The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment

1910.132(d)(2)
The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

An initial hazard assessment will determine whether or not employees are exposed to hazards above OSHA safety standards, thus requiring engineering and administrative controls to reduce exposure. If exposure to the hazard cannot be reduced below safety standards then respiratory protection and personal protective equipment must be implemented to protect employees. Additionally, the results of a hazard assessment will help the employer identify the type of personal protective equipment (PPE), respiratory protection, filter selection and the filter change out schedule, which are all required when protecting employee’s from a hazardous contaminant such as mercury. Lastly, your hazard assessment must be documented and available for inspection.

Occupational Mercury Exposure

“But I was taught mercury doesn’t escape from amalgams!” We have heard this refrain from dentists more times than we’d like to admit. Fortunately, to help bring clarity to this issue there are many examples to be found in the scientific literature and surprisingly even from national dental organizations stating that mercury is released from amalgam fillings.

Below is a short authoritative list of those government entities, organizations and manufacturers who warn that mercury is released from amalgam fillings during  the placement, polishing and removal of amalgam fillings.

With such a large body of published literature indicating mercury exposure while working with amalgam, OSHA will expect you to have performed a hazard assessment to determine your employee’s exposure and will not accept that you were told in dental school that the mercury is retained within the amalgam. Not performing required tasks or having proper documentation can result in citations and fines from OSHA as well as lost of trust with your most valued asset, your employees.

Proper Implementation of Respiratory Protection

Upon realizing that mercury vapors generated during the removal of amalgam dental fillings exceeds safety levels, dentists and practice owners will likely want to implement respiratory protection for employees right away.  However, before hastily purchasing respirators, it’s important to know if your employees may have any potential health conditions that would prevent them from wearing a respirator such as lung disease, heart conditions and even psychological conditions like claustrophobia. For these reasons, OSHA  requires employers to evaluate if the employee is medically able to wear the respirator.

1910.134(e)(1)
The employer shall provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee’s medical evaluations when the employee is no longer required to use a respirator.

Workers are required to be medically evaluated using the OSHA suggested medical questionnaire or an equivalent method.  OSHA requires that the employer pays for the medical evaluation and that, if necessary, they give the employee the time off to have the evaluation or follow up performed. Luckily, there are also online medical evaluations, which save both time and money when having the initial evaluation completed. While there are no yearly medical evaluations requirements, all medical evaluations must be documented and available for inspection.

Benefits of utilizing the Online Respiratory Medical Evaluation:

  • Complete questionnaire in 15-30 minutes
  • Immediate notification of clearance
  • Can be used with any brand of NIOSH approved respirator
  • Exam can be taken on any computer or tablet with internet access
  • Online record keeping tracks employee’s clearance status
  • Available 24/7-Schedule at your convenience
  • 97% average pass rate (due to built-in expanded questionnaire)
  • Physician or other licensed health care professional (PLHCP) provides review and, if needed, will follow up with employee
  • Questionnaire available in English or Spanish

Respiratory Protection: Fit Testing & Training

Once an employee has been approved to wear a respirator, they must be given at least two choices when choosing the style of respirator provided by the employer (29 CFR 1910.134). The level of respiratory protection is primarily dictated by the results of the Hazard Exposure, although employers and employee’s may opt for respirators that provide more protection, not less.  After choosing a respirator, employers are required to provide a respirator fit test which will ensure the respirator will protect the employee from the air contaminant. Adequate respirator training that covers donning, doffing, cleaning and storage of respirators should be completed and must be documented before the employee uses the respirator as part of their work functions.

DENTAL SAFETY SOLUTIONS offers a complete OSHA respiratory protection package that includes the written respiratory program, filter change-out schedule, online medical evaluation, train the trainer session, qualitative fit test, respirator, filter and cleaning wipes. Filters can be set to automatically ship monthly.

OSHA Compliance for Respiratory Protection Program

Complete OSHA Respiratory Protection Program 29 CFR 1910.134

Complete OSHA Respiratory Protection Program with Training & Medical Evaluation Package

  • Online Respirator Medical Evaluation
  • OSHA – Written Respiratory Protection Program 29 CFR 1910.134
  • Train the Trainer: Respiratory Protection Program certification up to 3 employees
  • Qualitative Fit Test Kit w/ Test Hood, 2 Nebulizers, Bitrex and Instructional DVD
Complete OSHA Respiratory Protection Program with Training, Medical Evaluation & Fit Test Package
SMART Respirator Combo Pack #3M 7500 P

SMART Respiratory Protection Package: 3M7500P

  • 3M Half Mask 7500 series respirator in either sm, med or large
  • 2 mercury vapor cartridges with particulate filters (one pair)
  • Reduced rate monthly filter change-out subscription option
  • 100 alcohol-free respirator cleaning wipes
  • Add more quantities to shopping cart
  • OPTIONAL OSHA SERVICES & PRODUCTS
  • Online Medical Evaluation
  • OSHA – Written Respiratory Protection Program 29 CFR 1910.134
  • Train the Trainer: Respiratory Protection Program for up to 3 employees
  • Employee obtains Certification of Respiratory Protection Program Administrator
  • Qualitative Fit Test Kit w/ Test Hood, 2 Nebulizers, Bitrex and Instructional DVD
SMART Respirator Combo Pack #3M7500P

Do your own test: Rent a Mercury Vapor Analyzer

There will be some dentists who doubt that mercury is released from amalgam fillings. We get it. Your dental school didn’t tell you anything about occupational safety regarding dental mercury or respiratory protection. Many national dental organizations don’t mention anything about protecting yourself or dental staff members from dental mercury exposure and the FDA proclaims amalgam is safe for patients. These factors all add up, making it a challenge for you to accept the reality that mercury is released from amalgam fillings and that as a business owner you are obligated to inform and protect your employee’s from these toxic exposures.

So, in order to encourage you to embrace science and discover for yourself that mercury is in fact released from amalgam fillings, we offer weekly rentals of the Mercury Tracker 3000xs; a portable mercury vapor analyzer from Mercury Instruments USA. Now you too can perform the same tests as in the video’s on this page, in the privacy of your office.

If you want to know where you should measure for mercury, then check out the amalgam position paper by the International Academy of Oral Medicine & Toxicology. They have compiled a huge list of scientific studies indicating which dental procedures release mercury. Again, we implore you to please wear respiratory protection when performing any measurements of mercury.

Other Respiratory Protection Factors

Our goal at Dental Safety Solutions is to help all dental professionals to be knowledgeable about the many occupational safety standards that apply to them. We will be providing a number of resources to help dental professionals better understand how to be in compliance with OSHA’s Hazard Communication Standard (29 CFR 1910.1200), the Personal Protection Standard (29 CFR 1910.132.) and the Respiratory Protection Standard (29 CFR 1910.134) Additionally, there are a number of other key mandatory factors that are required by the Respiratory Program that we will cover in future articles such as.

  • Assigning a qualified Administrator to oversee the Respiratory Protection Program
  • Components of a written Respiratory Protection Program (with downloadable examples)
  • Hazard Assessment: checklist and resources
  • Use of engineering controls and work practices to limit employee exposure.
  • Guidelines for proper selection of appropriate respiratory protection
  • Medical evaluation / clearance
  • Respirator fit testing
  • Employee respirator training
  • Inspection and maintenance of respiratory protection equipment
  • Record keeping responsibilities

Additional information about OSHA’s Respiratory Protection Program can be found in OSHA’s small entity compliance guide for the respiratory protection standard.

If you have any questions, please leave them in the comments below.

2019-05-07T11:37:25-05:00

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