Grade Apple

OSHA Fines: Could this have been prevented?

You’ve been dealing with OSHA since you opened your practice (or longer if you happen to recall the days before gloves, masks or glasses), but what does OSHA really require? One Illinois practice thought they were doing everything correctly, but found themselves owing OSHA over $53,000 in fines this summer.

What if you had to grade your OSHA compliance inspections the way restaurants undergo health inspections? In most states, restaurants are required to display their reports or make them available upon request. Would you be proud to post your inspection results?

Many dentists tell us they feel they are doing “pretty good” when it comes to OSHA compliance, but is that good enough? How can you be sure this won’t happen to you?

In the Illinois instance, the practice was cited for several bloodborne pathogens violations, including:

  • Did not establish bloodborne pathogen exposure control plan and hazard communication programs at either location.
  • Failed to require the use of appropriate gloves and personal protective equipment.
  • Did not provide medical evaluation and follow-up to employees after an exposure incident.
  • Failed to make Hepatitis B vaccination series available to employees.
  • Did not train workers about chemical and bloodborne pathogen hazards and precautions.

Violations of the Hazard Communication Standard included:

  • Secondary containers of hazardous chemicals not appropriately labeled. (Note: secondary containers hold liquids you’ve placed in a different container for more than a one-time use.)
  • Safety data sheets not available.
  • Employees not trained on the Hazard Communication Standard.
  • No complete list of hazardous chemicals.
  • No method to inform employees of the hazards of non-routine tasks.
  • No method to inform other employers of safety data sheet availability or the labeling system and any precautionary measures to protect employees. (Note: This would apply if you use an outside janitorial company or share space with another practice.)

All employers, including dental offices, have a responsibility to ensure patients and staff are protected from injury and illness during procedures. Benjamin Franklin said, “If you fail to plan, you are planning to fail!” The important point here is to plan for compliance. If you are not clear on all the particular requirements of these two regulations, seek credible assistance. The Institute for Dental Compliance and Risk Management can provide you with a solid understanding of the laws and help you create a successful compliance strategy for your practice.