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From Your Regulatory Compliance Specialist – Linda Cannon – 9th Covid 19 Update.

MSDS-Dental OSHA and Safety
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!!
From Your Regulatory Compliance Specialist – Linda Cannon – 9th Covid 19 Update.
Contents from Your 
9th Covid 19 Update.  

 – Virginia Governor’s: How to Secure PPE through VDEM.  
MSDS Negotiates N95 NIOSH Approved Respirators.    
– Respirators Eligible for Authorization under The – EUA
– Fit Testing Requirements and Availability to Fit Test
– Staff Having Issues with Coming Back to Work?
– Pediatric Inflammatory Illness  
– Sunshine UV Light with Cage Design
– EPA has not stopped the Amalgam Separator Deadline
– When is it safe to be around others 
– Limitations of Infrared Thermometers
– Winner!

Gov. Northam stated on May 22, 2020: PPE shortages

Virginia has a great stock of PPE now, after earlier shortages, Northam reiterated, and said it’s available to any nursing home, prison, hospital, or similar facility that requests it through VDEM.   ….From Linda Cannon:  Below is VDEM’s information.  Is Dental Healthcare Providers considered a Similar Facility?  They do not mention, Out-Patient surgery centers, Physicians, or Dentists.  Clearly we are just as involved with our patients as a Nursing Home.  Everyone will need to start emailing this Agency and see if we can get anywhere.  The Governor also stated that “If the correct process to request was completed, the nursing homes would be able to get them. No where on the VDEM’s website does it show the process, directions, forms, etc.  He said if you get the forms done, you could ask the If anyone gets a hold of this process, please forward it to MSDS.    Get In Touch With VDEM

The Virginia Department of Emergency Management is headquartered in Richmond, Virginia, with administrative offices at Trade Court and the state Emergency Operations Center located off-site on the grounds of the Virginia State Police headquarters. VDEM’s regional coordinators also maintain offices within their territories to serve as a base of operations for Local Support Services Division staff.

VDEM’s Headquarters
9711 Farrar Court
North Chesterfield, VA, 23236
(804) 267-7600 (Voice)
(804) 272-2046 (Fax)
[email protected] 
***Do not wait for this to start emailing VDEM. ***

***Urgent Notice*** 

In the updated EUA, FDA revised one of the eligibility criteria that had formerly allowed for the authorization of respirators based on review of test reports from recognized independent test laboratories submitted to the FDA by the manufacturer or importer. FDA has now removed all respirators that had been authorized under that criterion, regardless of whether they passed or failed NIOSH testing. 

The FDA removed over 50 face mask manufacturers from Appendix A, leaving only around 14 authorized firms. The Agency stated that it is increasing surveillance of Respirator face masks imported from China and will subject shipments to random testing.

MSDS has also ordered 1000 N95 NIOSH approved masks. Don’t worry – I am not ordering anything that they can’t show me certificates and we can match the manufactures code, etc. We ordered the Harley as seen in the:NIOSH-Approved N95 Particulate Filtering Facepiece RespiratorsUpdated May 12, 2020*AI        Private label of Guangzhou Harley Commodity Company, Ltd.external ic
We have also ordered 1000 individually wrapped isolations gowns.  They are already on a Cargo ship heading the the US.  As soon as it hits the US, then UPS will provide MSDS a tracking number.  Any office that wants to wait, I will just put the products on the vendor list.  But I could not sit by and wait any longer.  

Dental Healthcare Providers are going to be involved with PPE Needs and Issues for a very long time.  I need to know if the majority of my clients want me to Negotiate N95 Respirators and Isolation Gowns.   MSDS starts Negotiations tomorrow Tuesday 5/26th for NIOSH Approved N95 and Isolation gowns to be sent to your office.  I will be Negotiating the minimum to get these sent to your office by the end of this week.  I am very good at Negotiating, but still could use a lot of Prayers….  This will be a combined effort. Meaning, that if you approved, you do not have to pay for them –  since you have already paid for them through MSDS to purchase from the National Supply we use.  However, I am still a believer in purchasing the best pricing you can and keeping a hot iron in each supply house.  So if you like the price and I purchase them for you,   As far as the National Supplier goes, I will not delete your order (minimum at least you want N95’s and Masks from them also, and Nitrile Gloves since the Entire US will be wanting masks and gloves come the beginning of June.  I believe every office that ordered Nitrile gloves has received them or are on their way.  The National Supply will always ask me who I want to send the allocated amount of PPE.  I will ask the clients that have $ still in their account, but you will always get an email or text asking for permission.  Any office that has exhausted their account $,we will ask the office to go back in and order through MSDS and we should know the exact amount and cost of the PPE.  

Please make sure if you are a staff reviewing this Newsletter for the office, that you tell the doctor to keep an eye on the Next Newsletter as It will only have the information on N95’s, Gowns, and Thermometers (Temple or Forehead and Infrared).  

So if offices accept the price.  (EMAIL: [email protected] and let us know).  Just know that the best pricing is purchasing from 100K to 1 million N95 masks or Isolation gowns.  It typically is outrageous to also ship to each office.  MSDS can’t afford purchasing 100K to 1 Mil. in N95 and Gowns.  But I am on the phone tomorrow morning with my best Cowgirl Boots on, and wearing my mom’s best confidence power jewelry I inherited.  So I am confident!!  

As far as KN95’s.  If, and only if, they have the headband type vs. Ear Loop, I will look at that product.  If you have staff that doesn’t need Fit Testing and you want the Ear loops, I can see what I can do, but it will not be for this round of Negotiations.  

And for those that wish you could just wait to pay when the order is ready to ship out.  This is no difference then you paying for my classes when I lecture.  The amount of money we save gives you the loyalty discounts.  It makes MSDS work hard for you because you already paid.  That is a huge burden on our shoulders which makes us constantly think of ways to choose the path that keeps our reputation 5 stare and our clients wanting to use MSDS in the future.  Plus, I don’t have to worry about statements, or collections or phone calls, etc.  That is a great savings and I pay it forward with the loyalty discounts I give.  I hope this makes sense, and all of you understand why we do what we do.  

Q: Can we use expired gowns and surgical masks? Do they offer the protection needed?A: These products were designed to serve as protective barriers and thus FDA believes they may still offer some protection even when they are used beyond the manufacturer’s designated shelf life or expiration date. The user should visibly inspect the product prior to use and if there are concerns (such as degraded materials or visible tears) the product should be discarded. As a conventional capacity strategy, expired products may be used for training and demonstration purposes where barrier protection is not needed. Q: Do gowns and surgical mask provide protection from coronavirus?A: Gowns and surgical masks are intended to provide broad barrier protection. Please see current guidelines from the Centers for Disease Control and Prevention (CDC) on recommended use of PPE during the COVID-19 outbreak. At this time, FDA has not cleared, approved, or authorized any gowns or surgical masks for specific protection or prevention against the virus that causes COVID-19.Q: Can I reuse a cloth gown? From Linda: Lab coats that snaps up to the neck.  A: Yes. Cloth gowns that will not be used in a sterile field, such as surgery, can be reused if they are laundered in enzymatic detergent.  Many offices are using Scotch Guard to add to their Lab Jackets Protective Barrier.  Rescue Squads have been doing this for years.  And 1/2 cup of Baking Soda in your laundry will make the detergent an enzymatic.  


Lets Talk about:   Respirators Eligible for Authorization under The –  EUA

A disposable non-NIOSH-approved respirator manufactured in China that meets one of the following criteria is eligible for authorization under this EUA:

  1. It is manufactured by an entity that holds one or more NIOSH approvals for other models of FFRs produced in accordance with the applicable standards of authorization in other countries that can be verified by FDA; or
  2. It has a regulatory authorization under a jurisdiction, including the Chinese National

    **MSDS’s own add in from NIOSH – If the mask meets or exceeds the filtraton requirements but is an ear-loop mask, it will not pass the Fit Tests.  Since there is a potential that Dental Healthcare Providers will be dealing with Fit-Testing currently and in the future, best to find masks that are a Head-band type, not Ear-loop.

    Side note:  I was told my some Healthcare Providers in some hospitals that if they only had earloop masks, they were taking locking Barretts ( I tried it with Mini Carabiner ) it works great.  It will not pass for the Annual Fit Test.  But for the issue at hand, it seems to work.
     The National Personal Protective Technology Laboratory (NPPTL) – Here is the link again of the KN95’s, but do go into the link and review the reasons.  It may be an issue that is fixable in the near future, like adding a headband vs. an Ear Loop.

Fit Testing Requirements: 

From:  Kimberly-Clark

Respirator Donning Tips:  (Self Fit Tests Every Time You Put On a Respirator (N95; KN95, etc). 

  1. The NIOSH information side is placed on the bottom.
  2. Place one of the elastics on the crown of the head (at the point of greateststretch).
  3. Place the other elastic at the back of the neck below the ears. Be careful of earrings as they may catch in bands.
  4. Position the metal nosepiece up high on the bridge of the nose and hold tight with the thumb and forefinger. Do not let go until all positioning is complete.
  5. Hold the nosepiece of the mask with thumb and forefinger, while fitting chin into the bottom of the mask.
  6. If the subject’s cheeks pooch out of the mask, fit their cheekbones inside the mask, while holding the nosepiece tight over the nose.
  7. If the subject’s chin is shallow or concave, a gap can be felt under the chin. To eliminate this gap, place the lower elastic band up at the crown of the head with the other band. This narrows the gap underneath.
  8. Check the seal by inhaling rapidly while looking down at the mask. If the mask collapses and expands, even slightly, it is an indication that a seal has been achieved.
  9. Safety seal type respirators are recommended to assure a seal for all facial features. Note that with safety seals if the subject has a narrow or shallow nasal bridge, turn the inside clear plastic film upwards under the metal nose piece.

    Fit Testing Tips
  10. All long hair must placed behind the ears. Any hair caught inside the mask will prevent a seal.
  11. Men must shave so that all facial hair is inside the mask. Even one day’s growth of beard can prevent a seal. Men with beards can not be tested.  Approved Facial Hair noted above. 
    The subject must decide to either shave or use a positive pressure apparatus.
  12. Those with a stuffy nose and/or sore throat possibly due to allergy, upper respiratory infection and/or cold should not be scheduled while experiencing these symptoms.
  13. Make sure the subject has not smoked two hours or eaten one hour prior to the test.
  14. Send the subject to the rest room after the threshold test to ensure that the mouth, lips, and face are rinsed thoroughly with water between the threshold check and fit testing. Lemon water may be used to insure elimination of the sweet taste of the saccharin. Make sure the subject has conducted a user seal check. Is the mask collaps- ing when the subject breathes in?

Staff in need Of A Fit Test?
* MSDS is setting up appointments at our home office when we are not in a lecture.  Chesapeake 23322 area. We can keep a 10 foot radius for 5 staff at a time.  
* Until we know how long the average time to do the Fit Testing, email [email protected] and request time slots.  
* The cost, $50.00 a person.  No additional Fees or Testing.  
* Staff will receive the blank Confidential Medical Clearance emailed to your office and MSDS will be adding it to our store, but there will be no fee associated with the Medical Clearance Test.  
* We will also be adding a class on how to do a proper “OSHA Fit Test”, along with a kit and manual for those offices that want to complete the annual testing at their office. Whether you are wanting to have MSDS complete or yourself.  

Staff Having Issues With Coming Back To Work?  

 I have a lawyer friend who has written a letter for MSDS’s clients.  
Some staff will be fine coming back to work. Some staff will not.  Most of the staff, once they remember how long HEP B, HEP C and HIV live on the surface, tend to understand were we are with COVID-19.  

And a very wise Dental Healthcare Provider said “If we take the top 5 cities off the statistic map, we would be dealing with what we have always been dealing with.  Bloodborne Pathogens, Influenza, the Common Cold, and Allergies.  That the Associations (VDA and ADA) have a liability to deal with and can’t hold authority for those doctors that are not members.  They have great ideas, but no regulatory demands.  CDC and NIOSH are Recommendation Agencies – and even though many states say look at CDC, they again have zero Regulatory Demands.  Inspectors are from OSHA.  So to help my offices from the  staff “Fear”  coming back from Furlough and Unemployment, I give you a generic letter to help.  if you need more information, or extra help, you will be getting the Lawyers name and Email address if your purchase the generic letter.  Below is a sample of the letter.   You can go to our website: and Type in the Search Bar:  Covid-19 Return to Work Letter.  

Staff Member,
As of [date], 2020, our offices have re-opened and we are seeing patients.  As of the date of this letter, you are being asked to return to your previous work schedule

Besides the letter – suggestions to follow: 

1.  Take pictures of all of the operatories and how clean and product free the counters are. 

2.  Take pictures of the front waiting room. 

3.  A copy of your polices and procedures signed by all staff. 

4.  Screening of Patients and Staff and that all are being completed.

5.  Pictures of Staff wearing their PPE.  ( Some staff have been told to take pictures of themselves without PPE, even through they have PPE available)

6. Social Media has the similarity to the Media craze. They are telling staff what they can do to protect themselves…. but some of the comments are alluding to ways the staff could cause an OSHA inspection if they don’t get the full amount of $$ from unemployment, etc.  Remember if something is too good to be true – believe 20%.  

7. Get staff to sign document stating they have been part of the meetings and feel safe with the PPE, including all COVID-19 Policies and Procedures and know they have an open door policy to speak freely on their concerns.  

8.  And document, document, and document some more.  

9.  Some offices are even putting up cameras like the Wyze so the office can view any discrepancies that need to be addressed.    

10. Remember….. Your Office should always look at Protecting the office from a “Could They” comment.   Do Not Assume a Patient or another Healthcare Provider Wouldn’t.  This is not the time to be the Nurturing Provider only.  And I say that with Love in My Heart for all the Patients and Healthcare Providers.  Fear is out there.  Real Fear.  So again… Document in “Quotes” on Record-keeping and Document in “Quotes” for the Team and include pictures and policies.  

I have no issues stating this section on my newsletters as my clients have always be very proactive to make sure their staff is safe! 

I feel very sure that the Board of Dentistry is sending the text for the issues of dentists not doing anything.  And I have heard some dentists haven’t even asked staff if they feel safe so they can get their questions answered.  

Finally, Childcare and Unemployment. From the VA Governor:  

The Virginia Employment Commission, which manages the unemployment insurance program in the commonwealth, is overseen by the federal government and has to follow federal guidelines. 
 Because of that, while schools have been closed, their closure has provided a legally acceptable reason for unemployment, summer coming means that is about to change, and they’ll be federally mandated to stop unemployment benefits when that’s the provided reason.

I know this School below is helping Healthcare Providers, including Dentistry.  

Learn With Me Academy

All three of our locations are fully licensed. We are open from 6:30am to 6:00pm Monday through Friday. 

-424 Edwin Drive Va Beach 23462

-3152 Magic Hollow Blvd Va Beach 23453

-5705 Lynnhaven Parkway, suite 101 Va Beach 23464

 Pediatric Inflammatory Illness The Virginia Department of Health has reported the second confirmed case in the state of a pediatric inflammatory illness associated with the new coronavirus.

MIS-C, previously called Pediatric Multisystem Inflammatory Syndrome, is a new health condition associated with COVID-19. The CDC recently alerted doctors that the condition had reported been in at least 110 New York children, as well as children in other states.

According to the Virginia Department of Health, the first reports of the syndrome came from the United Kingdom in late April.MIS-C may cause problems with a child’s heart and other organs. According to the Centers for Disease Control, most children with MIS-C have a fever lasting several days and 
 Pediatric Inflammatory Illness May Show Symptoms of: 
Irritability Decrease ActivityAbdominal Pain Without Another ExplanationDiarrheaVomitingRashConjunctivitis Lack Of Appetite Red Or Cracked LipsRed Or Bumpy TongueSwollen Hands And Feet
 State health commissioner Dr. M. Norman Oliver, M.D., M.A. issued a letter with guidance on the syndrome to Virginia health care providers on May 15. “I urge all health care providers in Virginia to immediately report any patient who meets these criteria to the local health department by the most rapid means,” said Dr. Oliver. “All Virginians should take steps to avoid exposure to COVID-19 by practicing social distancing, frequent hand washing and wearing cloth face coverings if appropriate.”
MSDS’s Pick for UV light.  80W Sunshine Model.  Per OSHA, they still like the UVC lights to kill Covid-19 on the N95.  And this one is amazing and has a protective cage.  But look at all the additional details.  

Product Details360 degree uv sterilization, disinfection, mites, no pollution.2.4G remote control, 360-degree omni-directional operation, remote control distance.Intelligent control with built-in radar sensor, 30 seconds delay is enabled.Portable hooks are convenient, flexible and easy to operate.10000 hours service life, switching times can reach more than 50000 times, Reliable quality.254nm – 280nmApplicable to shopping malls, supermarkets, offices, hospitals, schools, bars, factories, hotels, homes and other public areas.Still negotiating Price.  But love this model.     

Let me know what you all think!!  
EPA has NOT pushed back the Amalgam Separator Installation Date of July 14th, 2020Dental dischargers that exclusively practice one or more of the following specialties are not subject to any of the rule’s requirements, including submission of a one-time compliance report to their Control Authority:Oral pathologyOral and maxillofacial radiologyOral and maxillofacial surgeryOrthodonticsPeriodonticsProsthodonticsMobile UnitsDental Offices That Use A Septic vs. City Sewage
  July 14, 2020 is still the compliance date, meaning the date that existing sources subject to the rule must comply with the standards in this rule.  

For more information, see EPA’s Web site:​eg/​dental-effluent-guidelines. 

In accordance with 40 CFR part 23, this regulation shall be considered issued for purposes of judicial review at 1 p.m. Eastern time on June 28, 2017. Under section 509(b)(1) of the CWA, judicial review of this regulation can be had only by filing a petition for review in the U.S. Court of Appeals within 120 days after the regulation is considered issued for purposes of judicial review. Under section 509(b)(2), the requirements in this regulation may not be challenged later in civil or criminal proceedings brought by EPA to enforce these requirements.

For technical information, contact Ms. Karen Milam, Engineering and Analysis Division (4303T), Office of Water, Environmental Protection Agency, 1200 Pennsylvania Ave. NW., Washington, DC 20460-0001; telephone: 202-566-1915; email: [email protected].

 ECO II+ Amalgam Separator (Mandatory) 3 Easy Steps to redeem a rebate of up to $200 + your choice between a free 1.25 Gallon Amalgam Bucket or a free 5 Liter BioSURF surface disinfectant for the purchase and installation of  the ECO II or ECO II+ Amalgam Separator
MSDS has not raised the price on this Amalgam Separator although the amount they are giving in Rebates or Free goods and the updated Product is well worth the cost.  One Unit = 10 Chairs!
Why the ECO II+ Amalgam Separator? The ECO II+ Amalgam Separator was engineered to be elegant, effective and simple. As the leading amalgam separator in Europe after 15 years of popularity there, the ECO II+ has recently taken the American market by storm as well.  The ECO II+ is known for its compact, easy-to-use design that is ideal for dental offices requiring amalgam separation.BENEFITS INCLUDE
 *Even easier installation and higher flow rate than previous version*No disruptive vacuum loss! Engineered to ensure no loss of suction.*Low cost, saving dentists hundreds of dollars compared to competing systems*Easy installation and automated recycling options*Online documentation and e-mail maintenance alerts*Flexibility to work with almost any vacuum system SYSTEM SPECIFICATIONS*ISO 11143 certified (exceeds ISO standards, achieving more than 99.3% filtration efficiency)*Pre-vacuum installation: up to 10 chairs and a tandem option for up to 20 chairs*Compact design: 8.7” x 8.7” x 13.8”*Works with wet and dry vacuum systems*Convenient installation*Easy replacement every 12 months or once full*Recycling certificates automatically sent to each office and available online 24/7*Made and engineered in Austria

The Limitations of Infrared ThermometersInfrared thermometers can be very useful when used in the right way and put to task in the right applications. However, before you can develop confidence in their ability to give fast temperatures, you must understand their limitations. 

Infrared thermometers: Only measure surface temperatures and NOT the internal temperature of food or other materialsRequire adjustments depending on the surface being measuredAre not thought to be as highly accurate as surface probes measurements of the same *surfaceCan be temporarily affected by frost, moisture, dust, fog, smoke or other particles in the airCan be temporarily affected by rapid changes in ambient temperatureCan be temporarily affected by proximity to a radio frequency with an electromagnetic field strength of three volts per meter or greaterDo not “see through” glass, liquids or other transparent surfaces – even though visible light (like a laser) passes through them (i.e. if you point an IR gun at a window, you’ll be measuring the temperature of the window pane, not the outside temp) 
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.    
 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.  

Linda L. Cannon
Director of Safety Compliance

Phone: 1-757-718-1515
Toll Free: 1-800-483-0223

Email: [email protected]

MSDS' best practices website is not a standard or regulation, and it creates no legal obligations, nor does it change any existing OSHA or other government standard or regulation. The guide is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace.