10 Ways to Prepare for an Unannounced OSHA InspectionDecember 4, 2013 | Category OSHA & HIPAA, Safety
Would your dental practice be able to survive a $76,500 OSHA fine? That’s the fine a dental office faced after just a single employee needlestick accident. The fine was severe because there was no written bloodborne pathogen exposure control plan, the injured employee was not sent for medical evaluation, and the source patient was not tested for hepatitis B, hepatitis C, and HIV.
This could have been avoided with OSHA preparation and compliance. While accidents happen and are unavoidable, a plan that initiates a proper response is the difference between an accident and a major OSHA violation. Being OSHA compliant is an important component for practice liability risk management.
Here are 10 steps that I recommend to dental offices to help comply with OSHA regulations and maintain maximum safety. These will get you started. To fully prepare your office, request an in-office training or visit drcDental.com.
1. Educate yourself on current OSHA regulations. Provide documented initial training for all new employees and annual training for all employees on all the OSHA standards that apply to dentistry and the hazards in your workplace (available on drcDental.com). Keep records for at least three years.
2. Twenty-six states have their own state OSHA plan. Check to see if there are additional rules that your state OSHA plan may require. Be compliant with local, state, and federal agencies that have rules and regulations that overlap with the OSHA regulations.
3. Have an updated customized compliance manual that includes all of the required written plans, including accident prevention, emergency response, bloodborne pathogens exposure control plan, hazardous chemical communication plan, infection control plan, and tuberculosis plan. Employees should know where the manuals are located and have easy access to them.
4. Maintain a current chemical inventory list and current safety data sheets. The safety data sheets must be maintained for products for at least 30 years from last day of use.
5. Make sure that any product that is removed from its original package is properly labeled.
6. Provide all the necessary personal protective equipment (PPE) for your employees at no cost to them. Train employees on the proper use, care, limitations, and disposal of PPE.
7. Follow the CDC “Guidelines for Infection Control in Dental Health Care Settings.” Establish a written infection control plan for the practice and follow it.
8. Use only Food and Drug Administration (FDA) approved medical/dental devices and products.
9. Have current required state and federal posters, signs, labels, forms, and logs displayed.
10. Perform all the necessary monitoring/testing at the appropriate intervals and document the results. Examples of what should be monitored include sterilizers, first aid/medical emergency supplies, eyewash stations, smoke/fire alarms, fire extinguishers, dental unit water lines, nitrous oxide, and radiation.
For more information, or for assistance with any of the above, request an in-office OSHA certification course.