Workplace Safety: OSHA’s 2016 top citations


No doubt you’ve heard the metaphor about picking low-hanging fruit first. Picking the fruit from the branches of fruit trees that are easiest to reach involves less effort and is easier to do.

In business, the expression is frequently used to refer to selecting the easiest targets first, usually the ones that require minimal effort or financial investment. Let’s apply the principle of low-hanging fruit to OSHA compliance. What easy targets can you identify in your office that need correction or improvement?

A good place to started is OSHA’s top 10 citations for 2016, covering all industries. See which ones apply to your practice:

  1. Fall protection
  2. Hazard communication
  3. Scaffolds
  4. Respiratory protection
  5. Lockout/tagout
  6. Powered industrial trucks
  7. Ladders
  8. Machine guarding
  9. Electrical wiring
  10. Electrical, general requirements

While fall protection, scaffolds and electrical safety are important across all industries, the low-hanging fruit for a dental practice is the Hazard Communication Standard. Remember, in 2013 OSHA adopted the United Nations Globally Harmonized System for Classification and Labeling of Chemicals (known as GHS for short). Did you implement all the updates? And while you’re checking, don’t forget to review the basic requirements of this standard as well.

Basic requirements of this standard include:

  1. A written Hazard Communication Program (HCP)
  2. A Chemical Inventory List, which is the list of chemicals in each product used in your practice
  3. Labels on secondary containers of hazardous chemical or dental materials, such as cold sterilant [that’s the proper spelling solutions
  4. Current copies of Safety Data Sheets (SDSs)—formerly known as Material Safety Data Sheets. These must be readily available and up to date.
  5. Employee training upon hire, annually and when new chemicals are used
  6. Safety equipment such as an eyewash station with an accompanying sign, heavy utility gloves (not purchased from the grocery store), goggles and chemical spill kit

The deadline for employers’ compliance with GHS was June 1, 2016. Several key GHS changes included:

  1. Implement new signs and posters utilizing the pictograms
  2. Train staff on the updates, which were due December 1, 2013, unless your state OSHA-approved plan had an alternate deadline, as was the case with the state of Washington.
  3. Archive your existing MSDS and collect the revised SDS
  4. Incorporate the GHS information into your Hazard Communication Policy

Not sure if your program is up to date? Check out the OSHA resources on the Tools and Resources section of the Institute membership site. Still need assistance? Post a question on the forum or reach out to one of the compliance consultants who are members of the Institute. Remember, select the easiest targets first!