By Leslie Canham, CDA, RDA
What if an OSHA inspector shows up at your office to conduct an inspection? Will your office pass with flying colors, or will there be costly citations? This article will help you prepare your office for an OSHA inspection.
OSHA, enacted by the U.S. Congress in 1970, stands for Occupational Safety and Health Administration. OSHA ensures safe and healthy working conditions by setting and enforcing standards. This includes offering training, outreach, education, and assistance. Two of the standards related to dentistry are the Bloodborne Pathogen Standard and the Hazard Communication Standard.
The Bloodborne Pathogen Standard requires dentists to protect employees who are at risk for exposure to blood and body fluid. This protection includes hepatitis B vaccination, training and information on bloodborne pathogens, and personal protective attire. All must be provided at no charge to employees. In addition, the employer must have written safety plans, including an exposure control plan.
The Hazard Communication Standard is also known as the “Employee’s Right to Know” law. The standard requires dentists to ensure chemical safety in the workplace. Information must be made available to employees about the identities and hazards of the chemicals. The standard requires employers to provide training, personal protective attire, information for labeling containers of chemicals, and to maintain Material Safety Data Sheets (MSDS).
The General Duty Clause requires employers to "furnish to each of his employees employment and a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." The clause also requires “each employee to comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act, which are applicable to his own actions and conduct.” Dentists and employees are both responsible for safe work conditions and adhering to OSHA requirements.
Use this OSHA inspection checklist to see if your office meets OSHA compliance:
- OSHA training should be conducted annually and documented.
- Documentation of training should be kept for three years.
- Hepatitis B vaccination should be offered to clinical employees within 10 days of employment.
- Documentation of immunity to hepatitis B vaccination must be kept on file.
- If an employee declines the hepatitis B vaccine, the employee signature must be on file.
- Keep the OSHA manual up to date. If you don’t have a current manual, you can use these models from the OSHA Web site at www.osha.gov/Publications/osha3186.pdf.
- Do you have an OSHA poster? If not, download one free from this OSHA Web site at www.osha.gov/Publications/osha3165.pdf.
- Do you have a copy of the Bloodborne Pathogen Standard? It should be in your OSHA manual. If not, you can download it from this OSHA web site at
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051. - Keep employee record-keeping and health forms on file.
- Keep record-keeping and health forms for the duration of employment PLUS 30 years.
- Make sure the eyewash station works properly, has cold water only, and that a sign designates its location.
- Keep fire extinguishers mounted on walls and currently charged.
- Keep emergency exits marked and unobstructed.
- Make an inspection of the office for safe work conditions such as electrical and trip and fall hazards.
- Review evacuation plans and protocols. If you don’t have evacuation plans, you can download samples from OSHA eTools at www.osha.gov/SLTC/etools/evacuation/evaluate.html.
- A first aid kit should be available for employees to use for minor cuts and injuries.
- Hand hygiene policies should be in place.
- Make sure Exposure Incident Protocol is current and reviewed annually.
- Provide Personal Protective Equipment (PPE):
- clinical jacket
- protective eyewear
- mask
- gloves (both exam and utility)
- Personal protective attire should be provided at no charge to employees.
- Reusable clinical jackets should be laundered and maintained by the employer at no charge to employees.
- Engineering controls, such as needle recapping devices or safety syringes, should be used.
- There should be an annual review and evaluation of safer sharps devices.
- Work Practice Controls should be employed to reduce risks when handling sharps.
- Hazard Communication Standard must be followed:
- Inventory of hazardous substances
- Organize Material Safety Data Sheets (MSDS) for each hazardous substance
- Place labels on containers not identified (secondary containers)
- Inspect all chemical containers for leaks
- Employees should be trained on proper use of and handling of hazardous substances
- PPE provided for handling chemicals
- Training and information on chemical spill, disposal, and cleanup should be provided
- Sharps containers should be located as close as possible to where sharps are used. There must be a spill-proof container, colored red or orange-red, and it must be puncture-resistant and have a biohazard label.
- An explanation of what labels, signs, and symbols mean (chemical, biohazard, radiation, etc.) must be provided.
- There should be an ergonomic plan to reduce incidents of musculoskeletal injuries.
Encourage each dental team member to review the OSHA inspection checklist in this article. OSHA compliance gives employees confidence that their office is a safe place to work. In addition, dentists will avoid harmful and costly accidents. OSHA compliance creates a culture of safety in your dental office. To receive a complimentary copy of a more detailed “Conduct Your Own OSHA Inspection Checklist,” send an e-mail to [email protected].
Author bio
Leslie Canham is a dental speaker and consultant specializing in infection control and OSHA compliance. She has more than 36 years of experience in dentistry. Canham is the founder of Leslie Canham Seminars, providing in-office training, mock inspections, consulting, and online seminars and webinars to help the dental team navigate state and federal regulations. Reach Canham at (888) 853-7543 or Leslie Canham.
