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Compliance Corner

Final Exam

A spot OSHA inspection need not be a nightmare. Doing all your homework ahead of time will help you pass—and bolster your reputation for workplace safety. BY LESLIE CANHAM, CDA, RDA, CSP

POP QUIZ! What will you do if an inspector from the Occupational Safety and Health Administration appears in your reception area with a mandate to inspect your practice? The stakes are high: One dentist was recently fined $53,000 for common OSHA violations. Don’t end up like that poor doctor.

Two primary OSHA strictures related to dentistry are the Bloodborne Pathogen Standard and the Hazard Communication Standard. The former requires dentists to protect employees who are at risk of exposure to blood and other bodily fluids. Such protection includes Hepatitis B vaccination, training and information on blood-borne pathogens, plus personal protective attire. All must be provided to the employee at no charge. In addition, employers must have written safety plans, including an exposure-control plan.

The Hazard Communication Standard is also known as the “Employee’s Right to Understand” standard. Requiring dentists to ensure chemical safety in the workplace and employee knowledge thereof, it took effect in 2013.

Another to be aware of: the General Duty Clause. This requires employers to furnish “employment free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Your team is on the hook, too: “Each employee [must] comply with occupational safety and health hazards and all rules, regulations and orders . . . applicable to his own actions.”

So much mandatory compliance! One way to stay on top of federal regulations is to appoint someone your OSHA coordinator and equip him or her with the tools to do the job. Start with a dental-specific OSHA manual. Check with your state dental association or visit ada.org to view its Regulatory Compliance Manual.

Your OSHA coordinator will also benefit from becoming a member of the Organization for Safety, Asepsis and Prevention (osap.org), dentistry’s leading resource for infection control.

Here’s a (partial) checklist outlining some of the key steps to take:

  • OSHA Bloodborne Pathogen Training conducted for new clinical employees
  • OSHA Bloodborne Pathogen Training conducted annually for all clinical employees
  • Documentation of OSHA training kept for three years
  • Hepatitis B vaccination offered to clinical employees within 10 days of employment
  • Documentation of immunity to Hepatitis B vaccination on file
  • Signed declination form for any employee who declines Hepatitis B vaccine
  • An up-to-date OSHA manual on site (if you don’t have a current manual, use those available at osha
    .gov/publications/osha3186.pdf)
  • An OSHA poster present and visible (if you don’t have one, download one free via osha.gov/publications/osha3165.pdf)
  • A copy of the Bloodborne Pathogen Standard on-site. It should be in your OSHA manual; you can also download it via osha.gov.
  • Employee recordkeeping and health forms on file
  • Keep records and health forms for the duration of employment plus, believe it or not, 30 years
  • Eyewash stations must be working properly: cold water only with signs indicating their location
  • Fire extinguishers must be mounted on a wall—always charged and inspected annually
  • Emergency exits marked and unobstructed
  • Inspection for safe work conditions such as electrical and trip-and-fall hazards
  • Evacuation plans reviewed. Don’t have an evacuation plan? Download samples via osha.gov/SLTC/etools/evacuation/evaluate.html
  • First-aid kit available for employees to use for minor cuts and injuries
  • Hand hygiene policies in place
  • Exposure Incident Protocol must be up to date and reviewed annually
  • Personal protective equipment and attire (clinical jacket, protective eyewear, masks, exam gloves, utility gloves) is provided at no charge to employees
  • Reusable clinical jackets are laundered and maintained by employer
  • Engineering controls (needle-recapping devices, safety syringes) are either used or with evaluation documentation provided as to why they were not used
  • Annual review and evaluation of safer sharps devices
  • Work practice controls used to reduce risks when handling sharps, such as a one-handed scoop for recapping needles
  • Hazard Communication Standard followed (hazardous substances inventoried; safety sheets for each hazardous chemical collected and maintained; labels placed on all secondary containers; all chemical containers inspected for leaks; employees trained on use and handling of hazardous substances; personal protective equipment provided; training and information on chemical spills, disposal and cleanup
  • Sharps containers located as close as possible to where sharps are used—must be spill-proof containers, red or orange-red, puncture-resistant, with a biohazard label
  • Explanations provided for labels, signs and symbols (chemical, biohazard, X-ray radiation)
  • Ergonomic plan to reduce incidents of musculoskeletal injuries

That’s a lot. (It’s also another reason to hire a dedicated OSHA coordinator.) But OSHA compliance gives your employees greater confidence their workplace is safe—and gives you peace of mind that your risk is greatly reduced.

You simply must create (or deepen) a culture of safety in your practice. A $53,000 fine is bad enough. A reputation for being a dangerous, poorly managed workplace would be far worse. •

LESLIE CANHAM, CDA, RDA, CSP is an authorized OSHA Trainer and PACE provider by the Academy of General Dentistry, specializing in infection control, OSHA compliance, HIPAA regulations and accommodating special-needs patients. She has worked in dentistry since 1972 and has devoted the last 20 years to educating dental professionals on how to comply with complex regulations. Email her at office@lesliecanham.com.