by Sam Barry, DMD
While inspections of dental offices have remained steady over the last few years, violations and fines have been increasing. Several states have found OSHA violations to be a source of revenue during this continued time of tight budgets. Although the percentage of dental offices that face inspection is still very small, don't take chances with the financial security of your practice. Unfortunately, it takes only one phone call from an unhappy employee or patient to put your business at risk.
A few weeks ago, I spent a Saturday at a local dental office. The dentist and I did a thorough walk-through of the practice with an OSHA checklist, searching for violations, verifying paperwork, and combing through practice records. Not our first choice for a weekend activity, but with the imminent threat of an OSHA inspection, it was urgently needed after a disgruntled employee had left the practice.
Fortunately, this is something most dental practices will never have to experience. But with the media attention that has been given to high-profile infection control violations and the increasing awareness of patients, OSHA compliance not only protects employees but can soothe patient anxiety as well.
Take the following actions to start your practice on the road to OSHA compliance.
1. Conduct your own Job Hazard Risk Assessment (OHSA self-audit)
Use an OSHA checklist to uncover potential violations that may require your attention and correction. This is a good exercise for the entire team to assist with in order to reinforce the importance of training and compliance. With the team's help, an OSHA self-audit should take no more than one to two hours. An OSHA inspector may ask to see your current Job Hazard Risk Assessment. Enlist an OSHA expert for guidance regarding any potential violations and what course of action is needed to become compliant.
2. Schedule OSHA training for team members
New employees should complete training immediately upon hiring. If it has been more than a year since your last training, the entire team should complete the course together. Document the training by recording the date, topics covered, name, and job title of each employee. This training record (log) must be kept for at least three years. When selecting your training course, here are some questions to consider. What are the credentials of the instructor? How many trainings has he/she conducted? What is the course structure and thoroughness? Does it include practical guidance and recommended resources?
3. Focus on bloodborne pathogens and the Hazard Communication Standards
These two areas alone accounted for 229 of the 274 citations issued to dental offices in 2013, and 84% of the penalties charged. Maintain a written Bloodborne Pathogen Exposure Control Plan, with all of the required elements, and update it annually. Make sure you have an updated written Hazard Communication Program with all the required components, including the new Globally Harmonized Standard. Bloodborne pathogens and infection control procedures are also likely to be the issue of most concern to your patients. They may be aware of HIV and hepatitis scares caused by various breaches in infection control. Be prepared to explain your sterilization process to patients, and the methods used to confirm that equipment sterilization was completed effectively. Various state dental boards are also taking a closer look at compliance with the CDC Guidelines on infection control in the dental health-care setting.
Protect your employees, patients, and practice with OSHA training and compliance. For more help with OSHA, visit www.HenryScheinBusinessSolutions.com.
Sam Barry, DMD, graduated from the Oregon Health Sciences University School of Dentistry in 1982. In 2006 he was certified as an OSHA trainer and has since presented over 200 WISHA and OSHA compliance classes for Henry Schein Dental. Call (800) 372-4346 or visit www.HenryScheinBusinessSolutions.com to learn more.
