Karson L. Carpenter, DDS
Many dentists are fearful of inspections by the Occupational Safety and Health Administration (OSHA). However, many do not understand that it is easy to mitigate the risks of inspections. Like other areas of liability that dentists have in their businesses, being proactive regarding OSHA always results in better outcomes.
For a few moments, let’s go through a scenario in which you imagine you are an OSHA inspector. As an inspector, you are a professionally trained college graduate, likely with a bachelor’s or advanced degree in industrial hygiene. Your employer, the federal government, encourages you to take continuing education courses geared toward making workplaces safer for employees. You truly believe that the businesses you visit should establish a culture of safety to protect those whom they employ. Whether inspecting a factory, a farm, a beauty salon, or a dental office, you expect that that employer has made provisions to keep his or her workers safe by following the requirements outlined by your agency.
You have been assigned to conduct an inspection at a dental office due to an anonymous complaint from one of its employees. The employee believes that the office is unsafe and that the employer is not following OSHA safety regulations. When you appear at the dental office front desk, there is obvious confusion. Clearly, the office is now in a state of panic. The receptionists quickly turn you over to the office manager.
You start the conversation by asking to speak with the individual in the office who is responsible for compliance. The office manager does not seem to know, but she thinks it is the doctor. You then ask to see the area where required documents such as the OSHA poster and the chemical inventory list are displayed. As it turns out, the practice does not have such documents posted and the office manager does not know where they are.
Next, you ask to see the practice’s collection of safety data sheets (SDS) and the written hazard communication plan. They do not have these, but one of the other employees thinks the dentist said they go to “some website” to get them.
Because you know that the employees are potentially exposed to blood every day, you want to review the office’s OSHA manual and its exposure control plan. The employees say they don’t have one. You ask to see the records of training for OSHA compliance, knowing that it is required yearly in every dental office in the United States. The office manager thinks they went to some OSHA seminar “a couple of years ago” and wonders if that counts.
At this point, you are feeling frustrated. Can anyone blame you? You see willful neglect. The business owner never even tried to protect the employees or get the office in compliance. Further inspection reveals that there is no eyewash and no training of employees on how to pick up chemical spills. You do note, however, the presence of many chemicals in the office such as disinfectants, cleaners, alcohol, bonding agents, etc. You find no familiarization with the requirements of the Globally Harmonized System (GHS), which is now required. You see a business owner with callous disregard for the safety of his employees.
Having been involved in numerous OSHA inspections of dental offices across the United States, I see a common element: OSHA inspectors are normally fair and reasonable! In fact, they rarely look beyond the basic (and achievable) requirements mentioned above. While this may surprise you, it shouldn’t. OSHA inspectors are a lot like us: they are well trained in their special areas, believe in what they do, and feel they can make a difference.
As dentists, it doesn’t really matter if we believe in, accept, or like the fact that OSHA regulations apply to our offices. What matters is that we are business owners and have a business that we must protect. Consider compliance with OSHA regulations as simply another form of liability insurance that you must have to protect one of your most valuable assets: your dental practice.
Author’s note: Contact your Henry Schein representative or visit HenryScheinBusinessSolutions.com to request in-office OSHA and infection control training for you and your staff.
Karson L. Carpenter, DDS, practices dentistry in Farmington Hills, Michigan, and serves as the president of Compliance Training Partners. He is a graduate of the University of Michigan School of Dentistry and has more than 25 years’ experience designing educational programs to bring dental and medical facilities into compliance with governmental regulations, including OSHA, HIPAA, and infection control.