Dental OSHA Compliance Checklist

May 9, 2024

POP QUIZ! What will you do if an inspector from the Occupational Safety and Health Administration appears in your reception area with a mandate to inspect your practice? The stakes are high: One dentist was recently fined $53,000 for common OSHA violations. Don’t end up like that poor doctor. 

Maintaining Occupational Safety and Health Administration (OSHA) compliance is paramount in dental offices to ensure the safety of both patients and staff. Failure to adhere to OSHA regulations can result in severe consequences, including fines, legal liabilities, and compromised patient care. In this article, we delve into the significance of OSHA compliance within dental practices, emphasizing its critical role in upholding safety standards and promoting quality care delivery. 

Importance of OSHA Compliance in Dental Offices: 

  1. Patient Safety: OSHA regulations are designed to safeguard patients against potential hazards present in dental settings. Compliance with these standards ensures that infection control protocols are rigorously followed, minimizing the risk of cross-contamination and the spread of infectious diseases. 
  1. Staff Well-being: Dental professionals are exposed to various occupational hazards, including exposure to bloodborne pathogens, chemical agents, and ergonomic risks. Adhering to OSHA guidelines helps mitigate these risks, protecting the health and well-being of dental personnel. 
  1. Legal Obligations: Dental offices must comply with OSHA standards to fulfill their legal obligations and avoid costly penalties. Non-compliance can result in fines, citations, and potential litigation, tarnishing the reputation of the practice and impacting its financial stability. 
  1. Reputation Management: Maintaining OSHA compliance demonstrates a commitment to excellence and professionalism, enhancing the reputation of the dental practice in the eyes of patients, regulatory authorities, and the community at large. 
  1. Continuous Improvement: OSHA compliance is not just a regulatory requirement but also an opportunity for continuous improvement. By implementing robust safety protocols and staying abreast of regulatory updates, dental offices can enhance efficiency, productivity, and overall quality of care. 

In the subsequent sections of this article, we will provide a comprehensive checklist tailored to dental offices, covering essential aspects of OSHA compliance. From infection control measures to employee training protocols, each item on the checklist serves as a roadmap for dental practitioners to assess and enhance their compliance efforts. 

Components of OSHA Compliance 

Two primary OSHA strictures related to dentistry are the Bloodborne Pathogen Standard and the Hazard Communication Standard. The former requires dentists to protect employees who are at risk of exposure to blood and other bodily fluids. Such protection includes Hepatitis B vaccination, training and information on blood-borne pathogens, plus personal protective attire. All must be provided to the employee at no charge. In addition, employers must have written safety plans, including an exposure-control plan. 

The Hazard Communication Standard is also known as the “Employee’s Right to Understand” standard. Requiring dentists to ensure chemical safety in the workplace and employee knowledge thereof, it took effect in 2013. 

Another to be aware of: the General Duty Clause. This requires employers to furnish “employment free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Your team is on the hook, too: “Each employee [must] comply with occupational safety and health hazards and all rules, regulations and orders . . . applicable to his own actions.” 

So much mandatory compliance! One way to stay on top of federal regulations is to appoint someone your OSHA coordinator and equip him or her with the tools to do the job. Start with a dental-specific OSHA manual. Check with your state dental association or visit ada.org to view its Regulatory Compliance Manual. 

Your OSHA coordinator will also benefit from becoming a member of the Organization for Safety, Asepsis and Prevention, dentistry’s leading resource for infection control. 

Here’s a (partial) OSHA checklist outlining some of the key steps to take: 

Infection Control 

  • OSHA Bloodborne Pathogen Training conducted for new clinical employees 
  • OSHA Bloodborne Pathogen Training conducted annually for all clinical employees 
  • Documentation of OSHA training kept for three years 
  • Hepatitis B vaccination offered to clinical employees within 10 days of employment 
  • Documentation of immunity to Hepatitis B vaccination on file 
  • Signed declination form for any employee who declines Hepatitis B vaccine 

Manuals and Record-keeping 

  • An up-to-date OSHA manual on site (if you don’t have a current manual, use those available at?osha.gov/publications/osha3186.pdf) 
  • An OSHA poster present and visible (if you don’t have one, download one free via  osha.gov/publications/osha3165.pdf) 
  • A copy of the Bloodborne Pathogen Standard on-site. It should be in your OSHA manual; you can also download it via osha.gov. 
  • Employee recordkeeping and health forms on file 
  • Keep records and health forms for the duration of employment plus, believe it or not, 30 years 

Workplace Safety 

  • Eyewash stations must be working properly: cold water only with signs indicating their location 
  • Fire extinguishers must be mounted on a wall—always charged and inspected annually 
  • Emergency exits marked and unobstructed 
  • Inspection for safe work conditions such as electrical and trip-and-fall hazards 
  • Evacuation plans reviewed. Don’t have an evacuation plan? Download samples via?osha.gov/SLTC/etools/evacuation/evaluate.html 
  • First-aid kit available for employees to use for minor cuts and injuries 
  • Hand hygiene policies in place 
  • Exposure Incident Protocol must be up to date and reviewed annually 
  • Personal protective equipment and attire (clinical jacket, protective eyewear, masks, exam gloves, utility gloves) is provided at no charge to employees 
  • Reusable clinical jackets are laundered and maintained by employer 
  • Explanations provided for labels, signs and symbols (chemical, biohazard, X-ray radiation) 
  • Ergonomic plan to reduce incidents of musculoskeletal injuries 

Sharps and Biohazard Safety 

  • Engineering controls (needle-recapping devices, safety syringes) are either used or with evaluation documentation provided as to why they were not used 
  • Annual review and evaluation of safer sharps devices 
  • Work practice controls used to reduce risks when handling sharps, such as a one-handed scoop for recapping needles 
  • Hazard Communication Standard followed (hazardous substances inventoried; safety sheets for each hazardous chemical collected and maintained; labels placed on all secondary containers; all chemical containers inspected for leaks; employees trained on use and handling of hazardous substances; personal protective equipment provided; training and information on chemical spills, disposal and cleanup 
  • Sharps containers located as close as possible to where sharps are used—must be spill-proof containers, red or orange-red, puncture-resistant, with a biohazard label 

Challenges of OSHA Compliance in Dental Offices 

Dental offices often encounter various challenges when striving to achieve and uphold OSHA compliance. One common obstacle is the complexity of OSHA regulations, which can be overwhelming to navigate for dental practitioners and staff members alike. Understanding the intricate requirements and ensuring full compliance with each regulation can pose a significant challenge, particularly for smaller practices with limited resources for dedicated compliance personnel. 

Another prevalent challenge is staff education and training. Ensuring that all dental team members are knowledgeable about OSHA regulations and proficient in implementing proper safety protocols is crucial but can be time-consuming and resource-intensive. Moreover, staff turnover or changes in regulations may necessitate frequent retraining efforts, adding to the complexity of maintaining compliance over time. 

To overcome these compliance challenges, dental offices can implement several strategies. Firstly, investing in comprehensive staff education and training programs is essential. By providing regular training sessions and resources on OSHA regulations and safety protocols, dental practices can empower their staff to confidently navigate compliance requirements and adapt to any regulatory changes efficiently. Additionally, establishing clear and efficient protocols for infection control, hazardous material handling, and emergency preparedness can streamline compliance efforts. By implementing standardized procedures and incorporating them into daily workflows, dental offices can ensure consistent adherence to OSHA guidelines, minimizing the risk of non-compliance and promoting a culture of safety within the practice. 

That’s a lot. (It’s also another reason to hire a dedicated OSHA coordinator.) But OSHA compliance gives your employees greater confidence their workplace is safe—and gives you peace of mind that your risk is greatly reduced. 

Further Reading 

What’s Next? 

We’ve delved into the critical importance of OSHA compliance in dental offices, emphasizing its role in ensuring patient safety, protecting staff well-being, and maintaining legal obligations. We’ve highlighted common challenges faced by dental practices in achieving and maintaining OSHA compliance, including the complexity of regulations and staff education requirements. However, we’ve also provided strategies for overcoming these challenges, such as investing in comprehensive staff education and training programs and implementing efficient protocols for infection control and hazardous material handling. 

For more detailed insights and practical tips on preparing for dental OSHA inspections, Benco Dental hosts regular webinars that help you earn CE credits while ensuring that you and your team meet annual training requirements and remain in compliance. You’ll receive valuable resources and guidance to help you navigate OSHA compliance requirements with confidence and ensure the safety and well-being of your patients and staff. To learn more about OSHA and infection control made easy for dentistry, click here or contact Benco Dental for more information.

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