OSHA compliance update

As a small business owner, your dental practice must comply with a variety of regulations, including those of the Occupational Safety and Health Administration (OSHA).

As a small business owner, your dental practice must comply with a variety of regulations, including those of the Occupational Safety and Health Administration (OSHA). While the real purpose of complying with OSHA regulations is to provide a safe working environment for employees, you must also consider the effects of noncompliance on your business.

As of August 1, 2016, OSHA penalties have increased 78%. Fines can now be up to $12,471 per serious violation and $124,709 per willful violation. Worse yet, the results of any inspection must be posted in a visible place in the office for all to see. Can you imagine the conversations your employees would have as they gathered to see the fines levied on you?

There is often considerable misunderstanding as to what OSHA regulates, and many confuse OSHA requirements with regulations for infection control. OSHA, in fact, is concerned with only one thing: the safety of employees. OSHA does not care if the hazard is from a chemical, blood-borne pathogen, electrical device, or fire. Its only concern is the protection of workers, and this includes those in the dental industry.

OSHA requirements for dental offices are wide ranging. They encompass electrical currents, ventilation, recordkeeping, radiation, first aid, fire, egress, working surfaces, blood-borne pathogens, and hazard communication. Most offices need to spend the majority of compliance efforts on hazard communication and blood-borne pathogens.

Annual retraining is required for existing employees, and training for all new employees is mandatory. Training programs must thoroughly review all aspects of employee safety, and must be documented in a written training log. The log must be signed by each employee.

The Hazard Communication Standard

The Hazard Communication Standard (HCS) deals with hazardous chemicals in the workplace. In dentistry, these include disinfectants, restorative materials, acids, cleaners, and impression materials. HCS requires a written chemical safety plan, safety data sheets (SDSs) for hazardous chemicals and products, labeling of hazardous products, and training of employees who work with hazardous products. Manufacturers are responsible for providing proper labels on products and must make available SDSs for these products as well. The employer is responsible for labeling any "secondary" containers that materials may be transferred into.

The Globally Harmonized System for Hazard Communication

OSHA has adopted the Globally Harmonized System for Hazard Communication (GHS). As the name implies, the GHS is a way of communicating chemical safety hazards in a consistent manner throughout the world.

This new system standardizes SDSs and labeling for chemicals, regardless of whether they were manufactured in Europe, Asia, or North America. In addition to improving protection for people and the environment, the GHS will facilitate international trade. For example, in the dental industry many products come from the United States, Japan, and Germany. Now that the GHS is fully enacted, health-care workers will see the same type of product labels and SDSs on all products they purchase-no matter what the country of origin.

Blood-borne disease pathogens standard

Because dental office employees are exposed to blood and saliva every day, this standard is of extreme importance. Requirements include having a written exposure control plan, providing the hepatitis B immunization at no cost to employees, and making available personal protective equipment (masks, gloves, safety eyewear, long-sleeved protective clothing, etc.). In addition, employees must have interdepartmental meetings at least annually to consider safermedical devices.

As with all OSHA regulations, training is paramount. Employees must understand the modes of transmission for blood-borne diseases such as hepatitis B, hepatitis C, and HIV. They must also know what to do in the event of a needlestick or other exposure incident and have access to proper follow-up medical care.

Plan of action

Your first step is to commit to being in compliance. Next, choose which of your staff members should be involved in implementation. Determine if you would like to take on this task by yourself or enlist the assistance of an outside company. The Henry Schein Business Solutions Team has the ability to perform an in-office OSHA compliance audit of your facility and provide the required annual training for your staff.

Once you have achieved compliance, not only will the burden of worry be removed, but you will have created a safer workplace for all.


Karson L. Carpenter, DDS, serves as president and CEO of Compliance Training Partners. He has 25 years of experience designing educational programs to bring dental facilities into compliance with governmental regulations. These include OSHA, HIPAA, and infection control.

Jim Philhower, a 28-year veteran of the dental industry, is the director of North America dental sales leadership and development for Henry Schein Dental. He teaches dental teams around the world techniques to help them reach their practice goals. Contact him at (800) 372-4346 or jim.philhower@henryschein.com. Learn more at HenryScheinBusiness Solutions.com.

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