Here's the latest list of Fiscal Year 2020 most cited OSHA Standards in Dentistry along with tips to help you in your dental practice or laboratory.
Each year OSHA publishes the top 10 most frequently cited standards for the prior fiscal year. The latest list is for the Fiscal Year 2020 which is from October 1, 2019 to September 30, 2020.
SafeLink Consulting has compiled a list of the top standards cited by OSHA violations for dentistry from OSHA's FY 2020 information.
Most Cited OSHA Standards in Dentistry Including State OSHA Agencies for FY 2020:
1) Bloodborne Pathogen Standard [1910.1030]: 86 Violations
In dentistry, the Bloodborne Pathogen Standard continues as the number one violation. If your workers are exposed to potentially infectious items you must have a written Exposure Control Plan and review that Plan annually. Tip: Always document your Exposure Control Plan review with employees so you have something in writing to show OSHA should you be inspected.
Biohazard waste handling within the workplace and sharps also fall under this Standard. Tip: The offer of the Hepatitis B vaccine was cited in several cases last year so make sure you have documented the offer to anyone who handles potentially infectious items. Remember to document the refusal of your offer and that’s for whatever reason. Refusal most likely is because the worker has already had the vaccine prior to employment with you. In this case they still need to sign your refusal.
Proper Removal of PPE for Infection Control
2) Respiratory Protection [1910.134]: 44 Violations
Compliance with the Respiratory Protection Standard was more familiar to dental laboratory owners prior to the pandemic than it was to dental practices. Now this standard is well-known with the use of respirators such as the N95 for protection during aerosol-generating procedures. The confusion to employers seems to come from determining if the use of respirators is voluntary or mandatory. Tip: When it is mandatory that means that the employer has directed workers to wear them during certain tasks. This requires first the completion and review by a medical physician a medical questionnaire. This service is available online through a number of companies so pretty easy to accomplish. Once it is determined that the worker is medically able to wear a respirator, then fit testing must be performed. This step is only necessary one time unless the brand or type of respirator is changed. That seems to be a misconception by employers right now and what even makes all this more difficult is the inability to reorder the same brand of respirator due to shortages. OSHA is strict on compliance with this Standard when respirators are required. When the use of them is voluntary, then the employer must provide a respirator if a worker requests it. OSHA requires the Appendix D document to be provided to workers. SafeLink Consulting recommends that you provide a copy to the workers and have them acknowledge receipt of the document. Appendix D states that the employer will provide the respirator but the worker agrees to wear it, store it, and dispose of it correctly. Learn more about respiratory protection.
3) Hazard Communication [1910.1200]: 40 Violations
In regard to Hazard Communication this is about chemical hygiene. This is the standard that requires employers to provide access to their workers to Safety Data Sheets, train workers on the hazards of chemicals, implement controls to protect workers, and label products with hazard warnings. As in other industries, this standard continues to be difficult for some reason for employers to comply with. Tip: An easy solution for Safety Data Sheets is to subscribe to SafeLink’s SDS Online Access service.
How to Achieve OSHA Compliance for Dentistry
Other Cited Standards in Dentistry Include:
4) Training – 6 violations
5) First Aid, exits, fire extinguishers and other emergency violations: 6 violations
6) Personal Protective Equipment [1910.132]: 4 violations
7) Miscellaneous: training, recordkeeping, wiring, air contaminants, and others: 44 violations
How to Achieve Dental Lab OSHA Compliance
Various sources have reported that during the pandemic, OSHA has received 15% more complaints in 2020 compared to 2019, however, they performed 50% fewer inspections. OSHA is using remote inspections by telephone, videoconference, or e-mail rather than onsite. Employers must respond within the designated time period. We’re seeing frequent follow-up to employer’s responses asking for even more information including documentation of written safety policies and policies for enforcement of the policies. Contact SafeLink Consulting for assistance with meeting OSHA Compliance.
Emergency Temporary Standards
OSHA has been criticized for not establishing a COVID-19 emergency temporary standard (ETS). Four state plans have issued their own ETS, i.e. VA (July 15, 2020), MI (October 14, 2020), OR (November 16, 2020), and CA (ETS on November 30, 2020 and has an Aerosol Transmissible Diseases regulation. If you’re located in any of these states contact SafeLink Consulting for assistance with meet the ETS requirement through use of its COVID-19 Safety Management Program. SafeLink Consulting developed this Infectious Disease Preparedness and Response Plan last summer when OSHA recommended that employers consider developing this plan. COVID-19 may not be the last communicable disease that we have to deal with so this plan provides guidance on how an employer will be better prepared in the future to handle this type of hazard.
“In a year that was defined by the ongoing pandemic, workplace safety became more important than ever,” NSC President and CEO Lorraine M. Martin said in a statement. “The OSHA Top 10 list reminds us why we must continue to focus on persistent safety risks as we navigate new challenges. These data help us pinpoint areas where we can improve so we can better prioritize workplace safety in the future world of work.”
Dentist Offices Affected By OSHA National Emphasis Program COVID-19
Other Most Frequently Cited OSHA Standards FY 2020
For General Industry the list didn’t change from FY2019 but the order changed slightly. Fall protection continues to be on the list for the tenth fiscal year and ladders is climbing. Respiratory protection rose to third place and will probably continue to climb in the current fiscal year due to the use of respirators for protection from aerosol-generating procedures.
The most frequently cited standards are evenly divided between construction and general industry standards. Dentistry falls within the general industry standards.
In FY 2020, the most frequently cited OSHA standards were:
- Fall Protection—General Requirements (§1926.501): 5,424 violations;
- Hazard Communication (§1910.1200): 3,199 violations;
- Respiratory Protection (§1910.134): 2,649 violations;
- Scaffolding (§1926.451): 2,538 violations;
- Ladders (§1926.1053): 2,129 violations;
- Lockout/Tagout (§1910.147): 2,065 violations;
- Powered Industrial Trucks (§1910.178): 1,932 violations;
- Fall Protection—Training Requirements (§1926.503): 1,621 violations;
- Personal Protective and Life Saving Equipment—Eye and Face Protection (§1926.102): 1,369 violations; and
- Machine Guarding (§1910.212): 1,313 violations.
Contact SafeLink Consulting for assistance or visit our website to learn more about how we can help your business.
Learn more about what SafeLink Consulting can do to help your business with compliance services, including safety compliance, to meet OSHA training requirements and quality system consulting to meet FDA compliance. SafeLink Consulting assists businesses with workplace safety training, infection control training, HIPAA training online, quality systems, assessments, audits, due diligence, and more.
Industries include:
Dentistry compliance - assisting the dental practice with meeting requirements for OSHA, HIPAA, EPA, and CDC guidelines, patient safety and employee health & safety
Dental Laboratory compliance - assisting the dental lab with meeting requirements for OSHA, FDA, and CDC guidelines, employee health & safety, plus FDA requirements for lab manufacturing custom implant abutment /gmp for medical device manufacturers
Medical Device Manufacturers compliance - assisting with meeting OSHA compliance & FDA requirements, GMP - good manufacturing practices
General Industry compliance - assisting with OSHA compliance and FDA compliance as it pertains to the specific business
Beverage Industry compliance - assisting beverage businesses such as the craft brewery, winery, cidery, distillery, vintner with meeting OSHA compliance, health & safety, FDA requirements / GMP - Good Manufacturing Practices.
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