Tag Archives: OSHA Compliance

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Dentists Loose $39,000 During (1) OSHA Inspection Visit! How Will Your Practice Stand Up to The Same Measures…?

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It can happen so unsuspectingly:  A quick-to-boil, disgruntled employee; An impulsive, disenchanted patient; And a simple phone call to OSHA.   One overlooked OSHA protocol– that leads to another– and then a third (as in this case).  The loose ends added up quickly when the OSHA Inspector began measuring this tally!

A Compliance Audit, like this one,… can quickly precipitate  disaster for the dental office, unaware of new changes in:  Infection Control , Required Waste & Recycling Containers & Dental Chair Unit Water Quality Regulations.  Oversights may be seemingly innocent: “We didn’t know that rules had changed”, “We are only a few months past-due for our OSHA Training Course” & “We just were not paying attention.”  Comments like these, should never be uttered by dental personnel nor touch an OSHA Inspectors ears.

Yet this incident, unassuming, well-intentioned dental office received (3) costly OSHA violations due to:  admitted negligence and obliviousness.  OSHA takes non-compliance seriously!  A major win for the OSHA Inspector; A $39,780 mistake for the (practice owner), Dentist.  Read on to discover how to avoid this plight and get your office on the road to comprehensive OSHA success!…

Did you know, that every January, www.osha.gov  & the Department of Labor Agencies, publish their new Penalty Increases.  Take a look at the 2019 “price-you’ll-pay” for ignoring to the 100+ Safety Protocols currently required to be operational in your dental office:

Type of Violation Penalty
Serious &
Other-Than-Serious

 $13,260 per violation
Failure to Abate $13,260 per day beyond the abatement date
Willful or Repeated $132,598 per violation
https://www.osha.gov/penalties/

The Penalties Inflation Adjustment Improvement Act of 2015 established an “Allowable Increase Rule” that lets these agencies adjust their assessed penalty levels, upward, every year.  And they do just that!  Since 2015, it seems OSHA & the DOL slap-on an average 10% increase to exceed the prior year’s average penalty rates. 

This year, the OSHA penalties will start at $13,260 per violation.  In addition, the maximum penalty allowed for “failure-to-abate” violations are $13,260 – that’s for every day that an employer fails to abate (1) specific violation!  Finally, the maximum penalty allowed for “willful or repeated” violations is $132,598!   This is 10 times the maximum permitted for “serious” & other-than-serious” violations.  These fees, undeniably, would be astounding and threatening to any dental practice.

What’s the cure?…

Get “in-the-know”!  Stay “in-the-know”, about current & evolving OSHA laws.  Make sure to include (3) components to build a truly comprehensive OSHA Program within your office: Annual Employee Compliance Training, All Required Paperwork & Up-to-Date Facility Protocols…

Incorporate Annual OSHA Employee Training for all employees. Be sure to include full-timers & part-timers; clinical as well as non-clinical employees.   Currently there are (45) Required OSHA Learning Point that should be covered in this year’s Annual OSHA Training.

Apply what you learn in your facility!  There are over 100 protocols to set up within your facility. Set your plan into action!  Its best to work with compliance trainers that provide a “recap” of your training in report format.  Then make sure you can reach your Trainers for additional guidance, clarification and support as you set up your protocols.  Getting the assistance during your set-up phase will be a critical key to your success.

Don’t forget the paperwork!  OSHA inspectors will check for required OSHA documents first!  When entering your office, they will want to see required documents, that are up-to-date.  Be sure to include:   Employee Forms & Acknowledgements, OSHA Manual written to GHS & Current CDC Infection Control Standards & new OSHA / GHS SDS Sheets in (2) varying formats.     

What do you do now?:  Get compressively compliant–then stay comprehensively compliant!   How?  Align with a compliance resource that provides “a relationship” along with your training, manuals, forms & protocol checklists.  One that you can reach out to 24/7 for guidance, clarification and updates.  We suggest this ALL IN ONE DXL Program.  It provides everything, plus, 24/7 access to Dental OSHA & HIPAA Coaches that become part of your team’s success.  It the relationship package.  And one of the best rated in the industry.

Need more guidance?  Contact an OSHA / HIPAA Coach for a confidential Discovery Meeting by calling 941-587-2864 or email us, anytime.  We are happy to help!

News and Blog

Beryllium & Silica additives in your lab products!

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Take notice: Recently, OSHA updated their requirements for dental offices and laboratories with regards to Silica and Beryllium dust. Both are common ingredients of dental materials.  The greatest take away from this article is making sure you check your labels and SDS sheets for Beryllium & Silica additives in your lab products.  Switch to non-Beryllium & non-Silica containing products and take proper precautions for a throughout clean up.  Now, let’s dig deeper into this topic…

Why the concern over these (2) elements? 

Over multiple year studies, dental labs have been found to have a higher occurrence of lung cancers and heavy metal poisoning, not only in the employees but also their family members at home. The tasks that are associated with this increased risk of beryllium and silicate exposure are casting, sandblasting, grinding porcelain, and cleaning/maintenance processes. The main culprit is the tasks is the materials used, they contain beryllium and silica dust. The particles are 1000x smaller than a grain of sand, allowing for them to become airborne and inhaled very easily.  Poor ventilation, respiratory protection, and barrier PPE increase the risk of inhalation. This fine particulate dust also settles on our uniforms, which if brought home, is then inhaled by family members. This significantly increases our family member’s potential to develop respiratory issues, cancers, and chronic health issues. OSHA has implemented regulations that are aimed at protecting dental lab employees and the secondary exposure victims. These regulations are coming under stricter enforcement measures within dental labs and adjacent dental practices. For more information on this please visit https://www.osha.gov/SLTC/beryllium/index.html, this outlines the OSHA findings to include how family members are affected by respirable silica and beryllium dust.

The final rule was published in June of 2017 after a few months delay by the current presidential administration. However, compliance is mandatory and will be rolled out for enforcement in the very near future. The timeline is as follows:

General Industry and Maritime

Comply with all obligations of the standard, except the action level trigger for medical surveillance

June 23, 2018

Offer medical examinations to employees exposed above the PEL for 30 or more days a year

June 23, 2018

Offer medical examinations to employees exposed at or above the action level for 30 or more days a year

June 23, 2020

The time is NOW, to begin implementing programs to reduce or eliminate exposures! You can be sure that dental practices and labs (that have exposure potential) will be audited very heavily. Primarily because these issues not only affect those directly involved but also second-hand exposures are very likely as well. An excellent resource that breaks this down even further is at http://news.nilfiskcfm.com/2016/08/silica-dust-glance-answers-7-faq-oshas-new-rule/. 

Risk Factors…

Without proper respiratory protection, the particles are inhaled into the lungs where they cause scar tissue to build up, reducing the lung’s ability to function. This is a condition known as Silicosis and along with chronic heavy metal exposure and poisoning (from the beryllium used in the materials). This condition can lead to kidney damage, lung cancer, and tuberculosis. Silicosis is an incurable disease that will cause chronic respiratory issues for life. Even if the exposure is stopped, Silicosis can, and usually does get worse. Silicosis is a preventable condition through the use of exposure controls, ventilation systems, and appropriate PPE.

Precautions & Exposure Controls…

How do we protect ourselves in regards to silicates and beryllium? The most effective method of control is through substitution. If we can eliminate materials that contain crystalline silicates and beryllium for sandblasting, then the main source of silicosis will no longer be present. A common replacement is aluminum oxide, however, there are many acceptable replacements available. If substitution is an option or not, focusing on ventilation at the production source of grinding is always a good idea.  And this is a Best Practice when crystalline silicates and beryllium are in use.   With an effective ventilation system in place, any dust that becomes airborne is evacuated before it is inhaled or caught on surfaces. In addition to appropriate ventilation, respirators are also required in case any stray dust is not captured. Respirators require proper FIT testing programs to be in place, either by a qualified member of the team or outsourced to a third party (approved testing methods are outlined by OSHA at  https://www.osha.gov/laws-regs/federalregister/2003-06-06-0 ). At a minimum, the filters on properly fitting air-purifying respirators must be N-100 type as defined in CFR 42 Part 84.179.

Proper Clean-Up, Disposal & Housekeeping Procedures…

In addition to the above control methods, some specific housekeeping procedures will help reduce the chances of exposure. Wet mopping ( with disposable mop-heads), wet wiping, or vacuuming with a HEPA filter is highly recommended to keep dust from becoming airborne. DO NOT use a compressed air duster, this will significantly increase the airborne particulates in both quantity and trajectory. Always be sure to double-bag disposable-mop heads and wet wipes into sealed plastic zip-lock bags and dispose of this waste in an exterior trash container.  When these items dry, the particulate matter can be reintroduced into the air.  Best to get them isolated and taken outside of the workplace.

Awareness & Action…

With the increased awareness of respirable silicate dangers in regards to dental settings, we can develop protocols and programs to decrease the exposure. Make sure to:

  • Check your lab products, replace all crystalline silicates and beryllium continuing products
  • Replace with non-Beryllium & non-Silica containing ingredients
  • Purchase proper ventilation safety stations
  • Wear proper personal protective equipment (especially respirators)
  • Never eat or drink in the dental lab area
  • Implement proper wet- clean-up with disposable wipes, zip-lock bag and isolate these items into exterior trash immediately

Most importantly, we can help to ensure all members of our dental teams, and their families, have a safe work environment and continued quality of life.

Provided by Dental Enhancements, Inc: 

Gabriel Muller USAF TSgt (Ret.), BA, NREMT, COHC

Heidi Muller  SSgt USAF, EFDA BS 

Jill Obrochta RDH BS 

For more information contact us at:  oshacoach@dentalenhancements.com

941-587-2864

Some additional sources of information pertaining to silicates and beryllium:

https://www.osha.gov/Publications/silicosis.html

https://www.osha.gov/Publications/osha3176.html

https://www.osha.gov/dsg/etools/silica/silicosis/silicosis.html

http://news.nilfiskcfm.com/2017/01/oshas-final-rule-beryllium-cuts-8-hour-pel-90/

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9734

Featured, OSHA

Dental Office: Where’s Your OSHA Tooth Fairy?

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It’s no joke, having to face OSHA Compliance (especially if you are the one in charge of it!) is a pain!  No worries, sit back click your heels together and we are about to make the pain subside.  Keep in mind these (3) factors and you will be flying high with OSHA compliance:

 

1.   Comprehensive Is Key!:  In 2013 OSHA compliance mandated that dental offices begin to implement the Global Harmonization System (GHS).  By December 1, 2013 it was required that all employees be trained to this GHS-Standard. Proof of this training is also required.  Your OSHA Manual will also need to be updated to this new GHS standard.  Finally, your required OSHA Employee Paperwork needs to be updated too.  Don’t feel overwhelmed or discouraged.  Simply choose a comprehensive GHS training solution.  This one seems to be written by the tooth fairy herself.  It’s logical and stress-free!

 

2.   Seek Expert Advice:  Plain and simple: Work with OSHA Experts! The new protocols are complex and “You don’t know what you don’t know…(but you need to!)  Don’t put your office at risk for a stressful OSHA inspection.  It’s not worth the agony. Be sure to choose an OSHA compliance company that will protect and guide you.  (This company makes it easy!)

 

3.   Are You Up-to-Date?  There is no excuse for non-compliance, And “not knowing” is not a good answer! GHS Standards will undoubtedly change and update.  Stay in-touch with a compliance company that will provide comprehensive yet easy-to-understand compliance updates.  Choose an OSHA Compliance Training Company that will share updates with you throughout the year and provide an interactive relationship.  You will gain comfort, confidence, and peace-of-mind.

 

Remember these (3) factors are the key to your OSHA compliance success.  The OSHA Tooth Fairy is out there.  Call her at 941-587-2864.

 

Written by Jill Obrochta RDH BS & Heather Whitt EFDA of Dental Enhancements.

 

 

 

News and Blog, OSHA

Dental Office: Is Free OSHA Really Worth It?

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We’ve all been there:  The Supply Rep brings in a decadent sandwich tray, you are eyeing the chocolate chip cookies, wondering if it’s worth the indulgence.  Then you decide, you really must munch on something sweet just to tolerate the next 45 minutes of OSHA yammering!  Is the free lunchtime OSHA really worth it?

Well, let’s face it:  Free is free. And while you may get a review of safety laws and the convoluted requirements of OSHA, nothing free really amounts to much.  Especially, when the OSHA Inspector shows up at your dental office ready to shoot holes through your Free OSHA Compliance Program.  (Uggh… Agida!  <hick-up>)

Let’s avoid the belly-aching and review the proper, comprehensive way to set up your OSHA Compliance Program.  A really good OSHA Compliance Program will have (3) components. Don’t leave any of these out:

1.   Have an Annual OSHA Employee Training Session

A proper OSHA Training Session requires you review and fully understand up to (23) areas of compliance.  Make sure you have a certificate that references all 23 areas and that all employees sign off on this.

2.  Obtain & Fill-Out All Required OSHA Employee Paperwork

There are (5) required forms for each employee to fill out.  Make sure your receptionists and part-timers are included in this paper fiasco too.  Everyone must comply.

3.  Make Sure Your Facility is up to Complete OSHA Compliance

Choose a compliance company that has expertise in all OSHA regulations for the dental office.  One that can offer a customized facility report for your office then help you get the recommendations into place.

So in the end, there really are no “free lunches”.  Get yourself aligned with an OSHA Training Company that provides the “whole enchilada”.  It’s easier on the palate and won’t come back up on you later.  <burrrp>

 

Written by Jill Obrochta & Heather Whitt of Dental Enhancements

 

Featured, News and Blog, OSHA

Dental Office OSHA: 3 Key Factors to Success

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Creating an OSHA Compliance Program for your dental office can be a daunting task.  If the thought of implementing or updating your OSHA program makes you cringe, want to pull your hair out or quit your job….Hang-in there, there’s help!

The key is to choose an OSHA Compliance Training Company that is comprehensive, hands-on with the required protocols and easy-to-work-with.  You want an OSHA Company that is “on your side” not policing for osha.gov.  Below are (3) Key Factors to keep in mind when creating or updating your dental office OSHA program:

 

1.    Be Sure your Program is Comprehensive:  In the recent year, there were sweeping changes with regards to OSHA compliance.  In 2013, OSHA mandated that dental offices begin to implement the Global Harmonization System (GHS).  This means that by December 1, 2013 you should have at least had your team trained to the GHS-Standard and be able to show proof of this training.  OSHA manuals will need to be updated to the GHS standard as well as your employee paperwork.  Proof-of-GHS-Training is a requirement, so you will want to have a GHS-Certificate or its equivalent.  Make sure to choose a comprehensive GHS training solution.  It will make your life with this new protocol logical and less stressed!

 

2.   Work with OSHA Experts:  New protocols?!!  Uggh!… that’s enough to realize:   “You don’t know what you don’t know…(but you need to!)  And Mr. OSHA Inspector….doesn’t care!”  Don’t risk being caught-up in an OSHA inspection and being called-out on not having these important and cumbersome new protocols in place.  It’s not worth the time and aggravation a prolonged OSHA Inspection is sure to bring. Choose an OSHA compliance company that will have your back and make it easy. (We love one in particular!)

 

3.   Update, Update, Update!  It never ends!  No, I’m serious.  Just because you get the GHS Standards under-your-belt and in place within your dental office, don’t think the buck stops there!  Compliance will always come with updates.  It’s the name-of-the game.  Again, make sure you choose an OSHA Compliance Training Company that will be your “OSHA dental tooth fairy”.  One that will share updates with you throughout the year and also maintain an interactive relationship with you so you can be comfortable and confident in getting your OSHA groove-on.  (What do you think they will leave under the pillow?)

 

Remember these (3) factors are the key to your OSHA compliance success.  Don’t be fooled, it’s not that easy.  Go search-out your OSHA Tooth Fairy now!

 

Written by Jill Obrochta & Heather Whitt of Dental Enhancements.