Table of Contents

Which OSHA Regulations Apply to the Dental Practice?

This isn’t as easy to answer as it may seem. 

This can only be determined after an assessment is performed by the practice to identify the hazards.  Then the appropriate OSHA Standards can be applied to make it a safe workplace.  If you are operating in one of the 28 OSHA-approved State Plan States, for example MN, CA or WA, you must comply with the State's requirements which may be different than those of the Federal rule.

The federal OSHA Standards that typically apply to a dental practice are:

  • General Duty Clause
  • Chemical Hygiene and the Hazard Communication Standard (HCS)
  • Bloodborne Pathogen Standard (BPS)
  • Emergency Action Planning
  • Personal Protective Equipment (PPE)
  • Radiation
  • Anesthetic Gases
  • Hearing Protection
  • Injury and Illness Recordkeeping
  • Other Hazards that may apply

General Duty Clause

Specific standards will be described below, however, it’s important for employers to understand that OSHA can also cite under the following sections which are referred to as the General Duty Clause.  They are: 

  • 29 U.S.C. § 654, 5(a)1: Each employer shall furnish to each of his employees’ employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."
  • 29 U.S.C. § 654, 5(a)2: Each employer shall comply with occupational safety and health standards promulgated under this act.
  • 29 U.S.C. § 654, 5(b): Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

You might say that this is a catch-all solution for OSHA for hazards that may not have a dedicated standard.  In the past, OSHA has limited its usage of the General Duty Clause when issuing citations, however, in recent years OSHA has increased issuance of General Duty Clause violations.  OSHA must be cautious when using this Clause and a violation under this Clause must meet certain criteria which include:

  • The hazard was recognized by either the employer or the employee.
  • Employees must be exposed to the hazard.
  • The workers exposed to the hazard must be employed by the employer.
  • The employer failed to keep the workplace free of a hazard to which his or her employees were exposed.
  • A feasible and useful method was available to correct or abate the hazard.
  • The hazard was causing or was likely to cause death or substantial physical harm.

There are several methods that can be used by OSHA to determine if a hazard was “recognized”.  The methods include the following:

Employer knew about the hazard and they could have been made aware of it through:

  • The employer’s job safety analysis: OSHA requires you to assess the hazards in your workplace and then act to eliminate or minimize them.
  • A previous OSHA inspection: If the OSHA compliance officer suggested a specific situation may constitute a hazard, then given the right conditions, the employer could be cited on a subsequent inspection for the hazard under the General Duty Clause. If you’ve been subject of an OSHA inspection and the compliance officer made any suggestions to you, you need to make sure that you’ve addressed them. 
  • A third-party audit or survey.
  • Employee complaints to OSHA or directly to the employer.
  • The industry that the employer is a part of has recognized a hazard. OSHA can view consensus standards or industry practices as recognizable.

The most important limitations for OSHA to cite under the General Duty Clause appear to be if the conditions of a serious injury or death are not met and if a specific OSHA standard exists.  It should also be noted that the General Duty Clause cannot usually be used to require a stricter requirement than what the standard requires.

Some examples of conditions that could fall under the General Duty Clause are musculoskeletal disorders (MSDs) resulting from hazardous lifting, repetitive tasks, or awkward postures that our work sometimes forces us to do, indoor air quality, and workplace violence.  OSHA is attempting to develop an ergonomic standard to deal with MSDs but until there is a standard, employers must still address ergonomic issues in their workplace.  Assess your workplace for all hazards and act to protect your workers whether there is a specific OSHA standard. 

Chemical Hygiene and the Hazard Communication Standard (HCS)

OSHA’s Hazard Communication Standard was last revised in 2012 when some of the components of the Globally Harmonized System were adopted by OSHA.  Some parts of HCS are technical, but the basic concepts are simple. If you use chemicals in your practice, then you must comply with the HCS.  This would include having the following:

The HCS covers both physical hazards (such as flammables, corrosives, and harmful dusts), and health hazards (such as irritation, lung damage, and cancer). Most chemicals used in the workplace have some hazard potential, so the HCS will probably apply to every product you use. One difference between this standard and other OSHA standards is that this one is performance-oriented. That means that you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements. It also means that you must exercise more judgment to implement an appropriate and effective program. This is where things get tricky. A good example of exercising judgment is how you choose to communicate hazards of chemicals to your employees.

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Identify Hazardous Chemicals in the Workplace

The standard requires an inventory list of hazardous chemicals in the workplace as part of the written hazard communication program. The list will eventually serve as an inventory of everything for which an SDS must be maintained. In the beginning, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your facility.

The best way to prepare a comprehensive list is to dig in and survey the workplace. The broadest possible perspective should be taken when doing the survey. Sometimes people think of "chemicals" as being only liquids in containers. The HCS covers chemicals in all physical forms - liquids, solids, gases, vapors, fumes, and mists - whether they are "contained" or not.

Look around, identify chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, dusts and exhaust fumes are all sources of chemical exposures. Read labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. For your own information and planning, you may also want to note on your inventory list the location(s) of the products within the workplace, and an indication of the hazards as found on the label. Even though this information does not HAVE to be listed, it will save you time and help you with your overall health and safety program.

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Employee Information and Training

Information and training are a critical part of the hazard communication program. Employees must be able to identify verbally the hazards of the chemicals that they’re working with.  Having SDSs and labeling containers is not enough.  Worker training must include learning how to read and understand this information, determine how it can be obtained and used in their own workplaces, and understand the risks of exposure to the chemicals in their workplaces as well as the ways to protect themselves.  Each employee who may be "exposed" to hazardous chemicals when working must be provided information and trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes. Virtual Safety Training + Assessment

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Get education in understanding the new classification, labeling, universal symbols and standardized safety data sheet by taking this online course, Employee Training – OSHA’s Revised Hazard Communication. 

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Bloodborne Pathogen Standard (BPS)

The BPS can be found on OSHA’s website as regulation 29 CFR 1910.1030.  This is a 16-page document that was adopted by OSHA on December 6, 1991 and became effective in 1992.  Its purpose is to protect healthcare workers from exposure to potentially infectious items.  As stated in an OSHA Fact Sheet on the BPS, “Bloodborne pathogens are infectious microorganisms present in blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV), the virus that causes AIDS. Workers exposed to bloodborne pathogens are at risk for serious or life-threatening illnesses.”  So, OSHA requires employers who have workers with these risks to comply with the Bloodborne Pathogens Standard.  Let’s review the requirements that are set out in the Standard.

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Establish an Exposure Control Plan

This is a written plan that establishes how the employer is going to eliminate or minimize potential occupational exposure to bloodborne pathogens.  In order to prepare the exposure determination, the employer must:

  1. Assess the workplace for this type of exposure.
  2. Prepare a list of job classifications in which all workers have occupational exposure (referred to as Category I workers) and a list of job classifications in which some workers have occupational exposure (referred to as Category II workers).
  3. Prepare a list of the tasks and procedures performed by those workers.
  4. Offer the Hepatitis B vaccine to workers who have potential exposure.
  5. Provide a procedure for Post Exposure Evaluation.
  6. Address disposal of biohazardous sharps.
  7. Determine appropriate personal protective equipment to protect workers.
  8. Use of Universal Precautions.
  9. Provide training to workers.

The assessment stated in Item 1 above is to be performed by employers to determine where it can be reasonably anticipated that workers encounter blood or other potentially infectious materials (OPIM) while doing their job duties. 

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The list of job classifications stated in Item 2 above can be a list by job title, such as, dentist, dental assistant, dental hygienist, sterilization coordinator, etc.  Safety procedures must also be prepared to identify the procedures that workers must take to protect them from OPIM. 

The Hepatitis B vaccine must be offered to workers who may encounter potentially infectious items.  In a dental practice this can be the dentist, dental assistance, dental hygienist, and sterilization coordinator.  If any other administrative workers would be required to clean treatment rooms after patient treatment, then they would also be offered the vaccine.  Workers can refuse the vaccine for any reason.  The employer must have the worker sign a refusal but be informed that should the worker change his/her mind in the future, the vaccine will be made available at no cost. 

Post-exposure evaluation and follow-up applies to any occupationally exposed worker who experiences an exposure incident. Some examples of exposure incidents in a dental practice would be (1) a needle stick with a contaminated needle, (2) splash or splatter into mucous membranes during patient treatment or when cleaning dirty instruments in preparation for sterilization.  When this type of exposure occurs, the employer must offer the evaluation at no cost to the worker.  It’s best to stress to workers to notify the dentist immediately of this type of exposure and preferably while the patient is at the practice.  The dentist would inform the patient of the exposure and ask the patient to consent to blood testing.  The employee is also offered blood testing.  The employer must maintain confidentiality of the results of the testing for the worker and for the patient.  Postexposure prophylaxis and counseling are a part of this procedure.  The incident must be documented.

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Update the plan annually

Health and safety programs must undergo review at a minimum annually in order to keep the program up-to-date and addressing current health and safety concerns.  OSHA requires that the Exposure Control Plan be reviewed annually. 

Training

Workers must be trained upon hire, if changes to their job tasks place them at a risk that is new their job, and annually. Get compliance training.

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Emergency Action Planning

Planning for emergency situations allows an employer to identify the types of emergencies that could be encountered in their facility.  Examples would be chemical spills, fire, medical, weather, and workplace violence. Here are some questions to ask yourself to help you assess how prepared you are for emergencies:

  1. Do you have training in place to ensure that employees understand the Plan? Train them upon hire, include an annual refresher training, and when additional emergency situations are added to the plan.
  2. Do you have up-to-date employee contact information? If an employee is involved in an emergency that requires you to contact a relative or friend who is designated by the employee, you must have up-to-date information. 
  3. Have the conditions for plan activation been documented and does everyone understand the conditions for Plan activation? Fire drills are a good example of testing your emergency evacuation plan.  OSHA doesn’t require you to conduct a fire drill but it’s a great way to test how long it takes for workers to evacuate the premises and if they gather in the designated assembly point.
  4. Does everyone who is responsible for any part of your emergency action plan understand their role as it’s set forth under the Plan? For example, if supervisors are responsible for having a list of their workers and a pen to take a roll when evacuation occurs are, they prepared with that information?
  5. Have you identified a potential alternate business location in the event you have to vacate your facility? That would also include locating offsite record storage; list of patients, vendor/suppliers.
  6. Have you designated the assembly area or safe “haven” in the building and the meeting place outside the building? Workers must be instructed that these locations have been determined in order to keep them safe from the emergency. 
  7. Do you have a plan for response after an emergency? In other words, if you evacuate the building who is the person who can determine that it’s safe for workers to return to the building.  Also, if the emergency involves a chemical release or explosion have you designated the person who can speak with the media?
  8. Do you review your plan annually along with things such as insurance coverage amounts? If you had a loss due to a fire or flood what did you learn from that and have you updated your plan to be more effective if the implementation of the plan didn’t work completely.  All of us learn from a bad experience from time to time, so you want to make changes that are necessary to realize positive results and make your workplace as safe as possible. 

Here are some emergency conditions to consider:  

  • Medical – heart attack, severe bleeding, foreign body in eye, burns, exposures
  • Fire extinguishment and alarm systems
  • Fire exits are clear and visible
  • Evacuation of facility
  • Spills – chemical and blood
  • Severe weather – snow and ice, flooding, tornado, hurricane, earthquake
  • Eyewash facilities
  • Evacuation routes – post maps
  • Special assistance needed for employees
  • Handling of patients under sedation or in surgery
  • Location of main gas shut-off valve

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Ensure that emergency equipment is well-maintained.  Some of the items on your maintenance checklist could be:

  • Monthly inspection of fire extinguishers (this is an OSHA requirement)
  • Annual inspection of fire extinguishers by an outside company
  • Daily check of an AED to ensure battery is charged if battery operated
  • Monthly check of supplies in the First Aid Kit
  • Monthly check of supplies in spill kits
  • Emergency oxygen cylinders are in working order

According to NIOSH more than 70% of American workplaces do not have a formal program or policy in place to address workplace violence.  Workplace violence is violence or the threat of violence against workers. It can occur at or outside the workplace. In today’s environment, no workplace is immune to the possibility of workplace violence and employers have legal duty and moral obligation to provide a safe workplace.  To prevent loss of life and injuries and to limit financial losses and potential liability, employers should institute policies and procedures to prevent violence from occurring in their workplaces.  These policies may include means to identify the potential for violence, procedures to prevent the occurrence of violence and, in the event, prevention fails, and an incident of violence occurs, plans to respond and mitigate further damage.

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Personal Protective Equipment ((PPE)

The OSHA Standards that apply to the selection and use of PPE are:

  • 1910.132 General Requirements
  • 1910.133 Eye and face protection
  • 1910.134 Respiratory protection
  • 1910.135 Head protection
  • 1910.136 Foot protection
  • 1910.137 Electrical protective equipment
  • 1910.138 Hand protection

After the employer has assessed the workplace to identify hazards and found that administrative and engineering controls don’t eliminate or minimize the hazards, then personal protective equipment must be provided.  If PPE must be provided, then

  • Select and have each affected employee use the types of PPE that will protect them from the hazards. Remember that OSHA can ask you during an inspection to show them why you selected a certain type of PPE. Having information on each type of PPE regarding its certification and description of what it protects against is a really good idea.
  • Communicate the selection decisions to each affected employee.
  • Select PPE that properly fits each affected employee.
  • Train employees how to wear the PPE, what maintenance is required to keep the PPE clean and in good condition, how to use the PPE, and when and how to dispose of the PPE.

Review the PPE requirements and selection at a minimum annually. 

Radiation

OSHA’s Standard 1910.1096 establishes the requirements to protect workers from ionizing radiation.  This protection can include the use of personnel monitoring devices and caution signs, labels and signals.  The Standard defines a dose as:

“Dose means the quantity of ionizing radiation absorbed, per unit of mass, by the body or by any portion of the body. When the provisions in this section specify a dose during a period, the dose is the total quantity of radiation absorbed, per unit of mass, by the body or by any portion of the body during such period. Several different units of dose are in current use. Definitions of units used in this section are set forth in paragraphs (a)(6) and (7) of this section.”

Exposures in a dental practice are typically measured by Rems.  The OSHA definition of a Rem is:

“Rem means a measure of the dose of any ionizing radiation to body tissue in terms of its estimated biological effect relative to a dose of 1 roentgen (r) of X-rays (1 millirem (mrem)=0.001 rem). The relation of the rem to other dose units depends upon the biological effect under consideration and upon the conditions for irradiation.”

When personnel monitoring devices are provided, the employer must make the results available to the workers.  Make sure that the workers understand what the results mean.

Radiation laws are also state-specific so the dental practice must consult with the state regarding registration of x-ray equipment and the state’s requirements for worker monitoring.

Anesthetic Gases

Dental workers are exposed to Nitrous Oxide (N2O) during administration of this anesthetic gas to patients. Exposures should be minimized to prevent short-term behavioral and long-term reproductive health effects that can be produced by N2O.

NIOSH research has shown controls including System Maintenance, Ventilation and Work Practices can effectively reduce N2O concentrations in dental operations to approximately 25 ppm during analgesia administration, the exposure limit recommended by NIOSH. Uncontrolled exposures to N2O have exceeded 1000 ppm. Learn more about the three methods of control.

OSHA has published a report titled Nitrous Oxide in Workplace Atmospheres (Passive Monitor) that indicates sampling methods for measuring nitrous oxide exposure. 

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Hearing Protection

OSHA has published information on their website indicating that approximately 30 million people in the U.S. are occupationally exposed to hazardous noise.  As reported by OSHA, this type of loss has been the most prevalent occupational health concern in the U.S. for more than 25 years.    

To provide guidance to employers, OSHA has published the following standards regarding monitoring and recordkeeping regarding noise levels:

  • 29 CFR 1904.10 Recording criteria for cases involving occupation hearing loss;
  • 29 CFR 1910 Subpart G Occupational Health and Environmental Control; and
  • 29 CFR 1910.95 Occupational Noise Exposure

Naturally exposure to high levels of noise are the cause of permanent hearing loss.  Short term exposures to loud noise can cause a temporary change in hearing, however, repeated exposures can lead to permanent tinnitus and/or hearing loss.  The effects of hearing loss are numerous.  It can create physical and psychological stress, reduce productivity, interfere with communication and concentration, and contribute to workplace accidents and injuries when it’s difficult to hear warning signals.

OSHA directs in their standards that an employer must conduct noise monitoring or measuring only when exposures are at or above 85 decibels (dB).  So how do you know whether the noise levels in your workplace are above 85 decibels?  Consider these questions:

  • Are your workers complaining about the loudness of noise?
  • Are workers complaining about ringing or humming in their ears when they leave work?
  • Are workers losing their hearing?
  • Are workers complaining about temporary hearing loss when leaving work?
  • Does the noise in certain areas of your facility make normal conversation difficult?
  • Does any of your equipment warn you about noise that is emitted during operation?

There are two ways to measure noise.  It is measured in units of sound pressure levels called decibels using A-weighted sound levels (dBA).  OSHA has set legal limits for noise exposure in the workplace.  These limits are based on a worker’s time weighted average over an 8-hour day.  The permissible exposure limit (PEL) established by OSHA is 90 dBA for all workers for an 8-hour day.  NIOSH recommends exposures to noise be controlled below a level equivalent to 85 dBA for 8 hours to minimize occupational noise induced hearing loss.

Injury and Illness Recordkeeping

All employers covered by OSHA must comply with Part 1904 regulations. However, most employers do not have to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics (BLS) informs them in writing that they must keep records. For example, employers with 10 or fewer employees and business establishments in certain industry classifications are partially exempt from keeping OSHA injury and illness records.

To determine if you are exempt because of size, you need to determine your company's peak employment during the last calendar year.

  • If your company always had ten (10) or fewer employees during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the BLS informs you in writing that you must keep records under § 1904.41 or § 1904.42.
  • If your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry under § 1904.2. Dental practices are partially exempt in most states so check our state requirements.

However, as required by § 1904.39, all employers covered by the OSH Act must report to OSHA: (1) within 8 hours any workplace incident that results in a fatality, and (2) within 24 hours an amputation, loss of an eye, or the hospitalization of an employee.  State plans may differ from this Federal requirement so consult your state OSHA plan for the exact reporting requirements.

Employers must post OSHA injury, illness summary Feb 1—April 30

OSHA’s electronic tracking and submission requirements also apply to certain employers:

  • Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and
  • Establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. Dental practices are not classified as high risk.

If employers in State Plan states have questions about their obligation to submit injury and illness information, please contact your State Plan office.

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Other Hazards

OSHA is paying attention to safety around walking and working surfaces, therefore, the employer must act to prevent slips, trips, and falls.  Electrical safety must also be addressed to ensure that workers are not exposed to electrical hazards.

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How Do I Assess the Health & Safety Risks in a Dental Practice?

To answer this question, we must understand the difference between a risk and a hazard.  

Not having a health and safety program would be a risk as it creates a chance of loss, danger or injury.  Assessing the hazards would be looking for any source of potential damage, harm or adverse health effects on something or someone. Get Virtual Safety Training + Assessment.

The first step is to identify the hazards that exist in your practice.  These are the typical types of hazards that may exist in a dental practice:

  • Biological hazards (exposure to potentially infectious items)
  • Chemical hazards (burns, damage to lungs and eyes)
  • Machinery hazards (rotating parts; flying debris)
  • Sharps use (percutaneous injuries by needles, burs)
  • Biohazard waste disposal (cleaning of treatment rooms, handling of biohazard waste)
  • Emergency situations (fire, severe weather, workplace violence, medical emergency)
  • Ergonomic hazards (musculoskeletal disorders like carpal tunnel syndrome, tendonitis, back pain)
  • Electrical hazards (can result in fire, burns, and even death; frayed and damaged cords, use of extension cords)
  • Walking and working surfaces (slippery surfaces, fall hazards)
  • Noise

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Conduct a survey of your practice with the above hazards in mind.  The survey can be conducted by:

  • Walking through your practice and observing employees performing their daily tasks;
  • Talking with your staff about the hazards they feel exist and how they protect themselves;
  • Hire a safety professional who is familiar with your work environment to help identify the hazards;
  • Use checklists to look for specific hazards that are available online;
  • Check the OSHA website for information;
  • Review past work-related injuries and any corrective action taken to manage or reduce the risk; and
  • Consider any past assessments that were performed.

Document your findings and then review the findings again with your employees to see if there is anything else they think should be added to the list.  After the list is complete, begin the process of assessing the control measures that have been implemented in your practice to protect employees.  These would include administrative controls, engineering controls, and the use of personal protective equipment.  If enough control measures have not been put into place, then determine what needs to be done to protect your employees from the hazard. 

Establish a timeline for correcting the unsafe practices.  Ensure that any changes are incorporated into the written health and safety program documentation.  Training of employees will be critical to the implementation of control measures.  This is particularly important if the new control measures require a change from the way things have been done in the past.  Seeking input from employees on how to correct these issues helps get their buy-in on the changes.

Determine how often this type of assessment will be conducted.  At a minimum it should be annually. 

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How Do I Develop a Health & Safety Program?

Here's six steps to developing a health and safety program for your dental practice.

Step One:  Have the knowledge of OSHA Standards

Employers can begin the process of developing their health and safety program by having a qualified person trained in hazard recognition conduct a thorough safety assessment of the workplace.  Discuss with the Safety Coordinator if they need additional training and knowledge about health and safety in the workplace and make a plan of action to assist that individual gain the knowledge needed.  There’s nothing worse than being responsible for something you don’t understand yourself.

There are many resources available for this step.  They include:

  • Hiring a staff member who has been educated in occupational health and safety
  • Hiring a consultant who specializes in health and safety in the dental industry
  • Provide education to a current staff member
  • Use OSHA’s Consultation service

Step Two:  Perform a hazard assessment

Conduct an assessment of the hazards in your workplace.  These could be chemical, biological, machinery, environmental, and/or physical.  This assessment should look particularly at any new hazards that have been introduced into the workplace in the past year.  This might include the purchase of new x-ray equipment, adding laser dentistry, or instituting sedation procedures.

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Step Three:  Take steps to eliminate or minimize hazards.

For each hazard identified, steps must be taken to eliminate or minimize them.  OSHA directs to use administrative controls, engineering controls, and the use of personal protective equipment.  An example of an Administrative Control would be changing the way a task is performed or removing the risk from the work area.  An example of a typical engineering control used in dental practices is providing safe devices for recapping needles.  If neither of these controls (administrative and engineering) eliminate or minimize the hazard, then personal protective equipment must be provided.

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Step Four:  Write programs

Many of OSHA’s Standards require written programs so it must be determined how the hazards that have been identified can be addressed in written programs.  Some examples of written programs are:

  • Hazard Communication Program (addresses chemical hazards, i.e. SDSs, labeling)
  • Exposure Control Plan (addresses biological hazards and infection control procedures)
  • Emergency Action Plan (addresses the emergency situations that could be experienced)
  • Radiation Policy
  • Personal Protective Equipment Assessment Program

The programs you develop will recognize the hazards and describe how they are being controlled to protect workers.

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Step Five:  Train workers

OSHA requires training of workers upon hire, when changes occur in the workplace that require training, and in some cases annually.  This link is to the OSHA guidance on training requirements.  Review the General Industry section of the publication - Training Requirements in OSHA Standards.  Also, if the dental practice is located in a state with a state OSHA plan, check on the training requirements as they can be more stringent than the Federal OSHA requirements.

Training must be conducted by individuals knowledgeable about the subjects of the training.  Information and materials provided by outside sources can be used in the training along with videos, online courses, or webinars, however, the training must be specific to the dental practice.  For instance, when emergency action planning is being covered, it’s important to discuss the location and use of the emergency equipment in place in the practice along with evacuation and severe weather gathering places.

Some examples of Training requirements are:

Always document the training activities.  The Training Register should contain the date and time of training, name and qualifications of the trainer, subjects covered, names and signatures of attendees.  Retain these records for your Bloodborne Pathogen training for a minimum of three (3) years. Other training records should be retained according to your policies, however, as a Best Practice it could be three (3) years.

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Employee Health and Safety in the Dental Clinical Environment:

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Step Six:  Evaluate the safety program

In recent years, OSHA has become more inquisitive during inspections about how the effectiveness of the safety program is measured.  The employer must be prepared to not only explain this process, but show documentation that the health and safety program is being reviewed and where needed it’s revised.

The most likely response to this inquiry may be that there have been minimal or no work comp claims.  This is fine and good, however, there’s more to this than work comp.  Develop a thorough system for evaluating the effectiveness of your safety program which should include documentation of those efforts.

Your evaluation could include the following:

  • Survey employees after safety training sessions to learn if their needs are being met.
  • Test employees before and after safety training sessions to measure their knowledge.
  • Evaluate the trainers to ensure they are delivering the information effectively.
  • Try various types of presentations to meet all learning needs – some people are visual and some learn better by reading or hearing information.
  • Assess your safety training program to determine if the company’s needs are being met.
  • Analyze accidents in order to ensure that the safety training is covering safe work practices that can eliminate the accidents.

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How Do I Train My Staff on Safety Practices?

Workplace safety training is a major requirement of most of OSHA’s standards. 

Employers must communicate workplace hazards to employees and instruct them on how to protect themselves from injury or illness.  Workplace safety training should include all company safety policies.

The objectives of safety training are:

  • To avoid and reduce injuries and illnesses of employees by providing appropriate information concerning the physical and health hazards that could be present in the dental practice.
  • To reduce property and/or environmental damage caused by dental operations, instructional activities or hazardous materials/chemicals used.
  • To comply with all applicable OSHA standards and any applicable state safety requirements.

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Training should be presented in a way that all employees can understand.  If employees have a disability or language barrier then employers should customize training for that worker.

After training activities, an employer should test employees to demonstrate employee retention of the information in order to evaluate the effectiveness of the training.  As an employer, you need to evaluate your safety program regularly to determine if additional training is needed to improve your workers’ safety and health.  As an employee, you need to inform your employer if you feel you need additional training on the hazards in your workplace.

All workplace safety training must be documented. Bloodborne Pathogen training must be kept on record for a minimum of 3 years. Other safety records should be retained according to your internal policies.

 The employer benefits greatly from workplace safety training. 

  • Employee training saves money by reducing injuries and incidents as it can result in lower insurance costs.
  • Safety training can boost an employee’s morale and increase production by making them feel like their employer cares about their well-being.
  • Workplace safety training will reduce employee downtime due to injury or illness, thus eliminating the need for employers to replace skilled workers who have been injured.
  • Proper employee training will help businesses avoid citations which result in large fines.

Most importantly workplace safety training helps ensure workers go home safe to their families.

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The National Institute for Occupational Safety and Health (NIOSH) describes a 7-Step process for safety training.  The steps are:

Step 1—Determining if Training Is Needed

Step 2—Identifying Training Needs

Step 3—Identifying Goals and Objectives

Step 4—Developing Learning Activities

Step 5—Conducting the Training

Step 6—Evaluating Program Effectiveness

Step 7—Improving the Program

Following these guidelines will assist in setting up an effective training program. 

Certain OSHA Standards have specific training requirements that employers must fulfill. Let’s look at these individual standards and review the frequency of the training: 

Standard/Topic:

Training Frequency:

Hazard Communication Standard (chemical hygiene)

Upon hire, when new hazards enter workplace

Bloodborne Pathogen Standard (Exposure Control Plan and Infection Control)

Upon hire, when new hazards enter workplace, annually

Personal Protective Equipment

Upon hire, when new PPE is required

Emergency Action Plan

Upon hire, when new emergency equipment is provided, when plan changes

Respiratory Protection

Upon hire, when type of respirator changes, annually

Radiation Safety

Upon hire and when new equipment is installed

Hazardous Waste

Upon hire, annually

Hearing Protection

Upon hire, as needed

Walking and Working Surfaces (slips, trips, falls)

Upon hire

Ergonomics (MSDs)

Upon hire

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Training Methods

Providing training in various ways can be more effective than using one method.  Here are some suggestions:

  • Lectures
  • Live Webinars or Virtual Training
  • Online Courses
  • Activities
  • Demonstrations

Lectures seem to be the least effective type of training because employees get distracted and in many cases bored.  Combining a lecture with a hands-on activity or demonstration can liven up the training session.  In our experiences at SafeLink Consulting, employees always comment on the “fun” activities that we incorporate into our safety training sessions.  We want them to look forward to next year’s training and not dread the safety training each year.

OSHA requires that the training be specific to the employer’s workplace.  This eliminates solely using a webinar or online course for training.  These venues can be used as a supplement to your onsite training.

The knowledge of the instructor is also important since OSHA requires that employees must be able to ask questions and have them answered by someone with the knowledge.  It’s also a plus if the instructor is energetic and knows how to engage the employees in the training.  This certainly helps employees stay focused on the training and retain the information.

Get a professional safety trainer.

Review training records and workplace safety policies and programs to ensure their effectiveness.  Make a plan of action to improve the training program if workers are having difficulty understanding how to apply your safety program to their job.  Review your safety policies to ensure they are covering any new technology being used or other new processes in place in your facility.

OSHA Compliance Solutions for the Dental Practice

Employee Health and Safety in the Dental Clinical Environment:

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Infection Prevention Coordinator Training:

 

How Do I Monitor and Enforce Safety?

So you have a formal health and safety program, train your employees on the hazards and how to protect themselves, but they still don’t follow the safety rules. Why?

Are safety rules enforced the same as attendance, punctuality, accuracy of work, etc.?  If not, they should be.  Review your constructive discipline procedures and include violations of the safety policies in the same manner.

Is management setting the tone for how safety will be received and complied with in the dental practice?  If the employees see their managers not following safety policies, not wearing the required PPE, or not enforcing the safety policy, then it will be very difficult to cultivate safety compliance.  Management must lead by example.

Is safety a team effort where one employee can remind another employee to wear their face mask correctly, for instance?  Managers can’t constantly monitor the use of personal protective equipment or the use of other safety tools, but should remind employees to follow the safety policies when they are not.  Employees should feel okay about reminding each other when a safety policy is not being followed.  Safety is everyone’s job.  Reminding employees in safety training sessions that safety is an important part of the culture in the practice helps to make this a team effort.

How engaged are the employees in resolving safety concerns?  During the year ask for employee feedback which is an important tool when cultivating safety compliance in your workplace.  However, employers should only use this process if they plan to follow-up on correcting the employees’ concerns and recommendations.  Asking employees for their opinion/thoughts and then not ever using their suggestions will hamper employee involvement.

How to Cultivate Safety Compliance

Employers can interview employees and:

  • Ask employees what safety concerns they have.
  • Ask employees what flaws they have identified in the safety of the work practices.
  • Ask employees what safety requirements actually create a hazard in the workplace rather than solve one.
  • Ask employees how they would report a work-related injury or illness.
  • And most importantly ask employees their opinion on how to correct any safety issues that may come up in the future.

In the Centers for Disease Control’s 2016 Summary of Infection Prevention Practices in Dental Settings, CDC recommends appointing an Infection Prevention Coordinator who performs frequent inspections of the infection control practices.  Assessing these practices more than annually provides an opportunity to close the gap more frequently on unsafe infection control practices.  This goes for all of the safety policies. 

Employers should communicate to employees the importance of reporting Incidents and Near Misses.  This information can be extremely helpful in identifying hazards and where better controls need to be implemented or workers need additional training.  Incident or near miss investigations would include the following:

  • Interviewing the employees involved in the incident;
  • A review of the work practices and hazard controls meant to protect employees involved in the incident;
  • The use of tools such as root cause analysis to help determine how to avoid a repeat of the incident; and
  • Finally the investigator’s recommendations to ensure there won’t be a repeat of the incident.

The practice should appoint a Safety Coordinator who has the responsibility for planning, implementing and overseeing the dental practice’s employee safety at work. Their main duty is to ensure that the practice is in compliance and adheres to OSHA standards to reduce work-related injuries.  The right person should be selected for this position.  They should be knowledgeable of the OSHA standards that apply to the dental practice, but also respected by co-workers and perceived as helpful rather than demanding. 

Safety doesn’t lie in the hands of one person.  The culture of your practice should include the importance of providing a safe and healthy work environment not only for employees but for patients as well.   

OSHA Compliance Solutions for the Dental Practice

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HIPAA Employee Need to Know:

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Whether you need a basic safety program to meet OSHA compliance or a comprehensive health & safety plan to protect your staff & patients we are available to assist you.

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I have been using SafeLink Consulting’s safety and privacy services since I purchased my practice. My major concern initially was about any safety liability I might be inheriting. The initial risk assessment helped me identify the areas where I needed to focus efforts to ensure a safe environment for my patients and my staff. The relationship that I’ve developed with SafeLink has been invaluable and they are an ongoing part of my staff safety training and program maintenance. They are professional, knowledgeable about dentistry, and provide a quick response to my safety and HIPAA needs. 

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M. Sajid, DDS Atlanta, GA

A huge thank you for making our OSHA training so stress-free and pleasant!  Everyone agreed your presentation was probably one of the best we’ve ever had.  And they’re a tough crowd!

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Julie B., Office Manager Dental Practice in Loganville, GA