Tag Archives: OSHA

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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.

 

 

 

Featured, News and Blog, OSHA

Dental Office OSHA- Do We Really Have to Train Annually?

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OSHA Training never brings a smile to your face. Thinking about this arduous task makes most of us cringe.  Seeing an OSHA Training Session, scheduled during your workday’s lunch hour is about as exciting as looking forward to doing your taxes.  Nonetheless, a necessary evil.

Not only is OSHA Employee Training required for your dental office to do annually, but every dental office employee is required to complete it.  This includes Receptionists, part-time employees, and even the Doctor!   If you pull a paycheck from the practice, you have to be there.  If you work at all within the office dwelling, you have to be there.

But let’s face it, not every employee may be able to attend the training in one set, given time.  What are you to do? Thanks to modern technology and more creative means of accomplishing training, select OSHA Training Companies can offer you the convenience of replicating or repeating your training session for absentee employees.  Even better, you should be able to obtain the training in a format that allows new-hires to train for free.

To accomplish this end, make sure to choose an Annual OSHA Employee Training Company that will provide the following:  Proof-of-Training Certificate, Handout for your Employees to Follow, Test of the Materials Presented, Live Instruction— either in person or better yet, via webinar and access to an OSHA Expert for future reference regarding questions, clarifications and access to important updates.

A 5-Star, Industry Rated program comes from Dental Enhancements. The Initial Annual OSHA Employee Training Package comes also with a 72-Point OSHA Safety Facility Report.  It is completed via the phone post-training session with one of your employees.  Recommendations for rectifying any Non-OSHA Compliant areas within your office are reflected in your customized report, making this program a superior OSHA training solution that most dental offices value.  It provides peace-of-mind for when an OSHA Inspector may “come-a-knockin” at your door.  Unlimited OSHA support—in the form of telephone or email access is also provided for one full year with this program.

Feeling inspired?  Much better huh?  So when you see that OSHA Training Session scheduled during your precious lunch hour now, you can smile not cringe.  It’s all about choosing the right OSHA Training coaches.  So, choose…Don’t snooze.  Don’t lose!

 

Written by Jill Obrochta & Heather Whitt of Dental Enhancements.

 

Featured, News and Blog, OSHA, Uncategorized

State vs. Federal OSHA Compliance: What You Need to Know

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It’s important to understand that OSHA Compliance is federally mandated.  But State Protocols may apply and these trump the Federal laws.  Pay attention, if you live in these States, you will have to seek out and apply the specific protocols within your State:

Alaska, Arizona, California, Connecticut, Hawaii, Iowa, Michigan, Minnesota, North Carolina, New Jersey, Nevada, New York, Oregon, South Carolina, Tennessee,  Virginia, Washington, Wyoming.

You may also want to take into consideration that where OSHA leaves off local Health Department Protocols & State Dental Practice Acts Rules may hold you more accountable as well. 

How do you keep track of all the many requirements that you may be subject to?  It’s hard to “know what you don’t know”.  Finding out the comprehensive facts can be next to impossible for the average dental practice.

 

Don’t sweat it.  Make sure when you are choosing an OSHA Compliance Solutions Company that you ask the right questions.  A good company will “hold-your-hand” over into “State Protocol and Dental Practice Act land”.   A unique feature that is value-added whenever you purchase any OSHA Training Package from Dental Enhancements is that you receive access to their private State Protocol Webpage for both OSHA & HIPAA specifications.  This takes the guesswork out of what you need and how to get it.  Ahhh— a huge blessing.

So now you know:  All OSHA is not created equal!  Align with an OSHA Training Solutions Company that will extend a hand and take you the full distance with your OSHA & HIPAA compliance obligations. 

 

Written by Jill Obrochta & Heather Whitt of Dental Enhancements. 

Featured, HIPAA, News and Blog

Top (5) OSHA Finable Offenses

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Are you OSHA inspection ready?  Do you know what OSHA inspectors will be looking for within your dental office?

It’s not only important to train your employees annually on OSHA Laws, it’s important to be aware of and prepared of OSHA inspector check-points.  Working with an OSHA Compliance Training Company that will provide insider tips for what OSHA inspectors focus on is critical.  Listed below are the top (5) finable OSHA offenses that are scrutinized most often within the dental office:

1.        Annual OSHA Employee Training—Make sure you sign up with a company that can provide reminders of the date you are due to re-train annually or one that has an OSHA Renewal Program.

2.       New OSHA GHS Proof-of-Training Requirement— GHS (Global Harmonization System) is a new federal mandate that standardizes chemical safety within the workplace.  All United States work facilities that have/ use hazardous chemicals or professional products needed to be trained in GHS with proof of this training by December 1, 2013.  If you are not yet trained in this OSHA /GHS area of compliance make sure to choose a simple yet comprehensive GHS Training solution.

3.       OSHA Manual written to the new GHS Standard— With the change in law to this new GHS Standard all of your OSHA paperwork, required forms and even the written standards  within your current OSHA manual will change.  Best to update and obtain a new one.

4.       OSHA Updated Employee Paperwork— There are (5) required documents for each employee in your dental office to sign and have on file.  Make sure again, that these are written to the new GHS Standard.  Need help?  Work with a knowledgeable and reliable OSHA Compliance Training Company that will supply all of these forms.

5.       Third Party Biological Testing— Most States require weekly testing of your heat sterilizer. (Exceptions are Arkansas & Florida which require proof-of-testing every 40 hours that you run your sterilizer).  The tricky part here is that if you have a failure, you must provide written proof that your sterilizer, and an alternate sterilizer prove the consistency of the failure.  Ugggh…this is enough to make your head spin.  Find and use a Third-Party Biological Monitor Testing company and have them send you official reports.  Save these on file for 3 years for your OSHA inspectors.

Of course there are many other considerations and regulations to follow.  Work with an OSHA Compliance Training Company that will provide an assessment of your facility and supply you with a customized report and recommendations for rectifying any of your non-compliant areas. 

So, what do you think?  Are you OSHA Inspection ready after reading this?  If not, stop procrastinating and find an OSHA coach that can help you scrutinize your OSHA status and let you get back to the art of dentistry.

Written by Jill Obrochta and Heather Whitt of Dental Enhancements.

Featured, News and Blog, OSHA

Is a sharps container required in each Dental Office operatory?

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To be compliant with OSHA guidelines, the answer is yes! Clinical employees should be disposing of soiled sharps in all operatories “at the point-of-use”. All used sharps (needles, carpules, damaged instruments and extracted teeth) which are contaminated with blood or saliva should be treated as if infectious. Sharps containers in your dental operatory should be part of your Engineering Controls and Work Practices per OSHA’s Blood Borne Pathogens Standard.

Not only are sharps containers required in each treatment room, so are small red bags. The logic here is to reduce the re-handling of any type of soiled waste, be it soft or sharp. It makes sense, disposing of soiled waste at the point-of-use immediately reduces the risk of infection and injury to the employee.

 

So, it becomes clear: employees cannot walk around or re-handle any soiled waste. Taking this into consideration, how do we accomplish this end without creating countertop clutter? Let’s face it, no one wants do have ugly red containers screaming biohazard in their operatories. Most times we want our ops to be relaxing and serene as well as aesthetically pleasing. We don’t want them to look clinical and potentially infectious, reminding patients of an uncomfortable hospital setting or worse. In recent years, dental offices have gone to great lengths to create the feel of a “day spa” not a biohazard wasteland.

 

How can we be compliant without sacrificing a peaceful, calm, aesthetic environment? While these sharps containers (and small red bags) do need to be present in the ops, they don’t need to be visible. Placing them in a cupboard is an easy way to keep employees safe and keep your operatory looking pretty. Another alternative is to have custom-cut, drop down disposal portals designed into your countertops. (Speak to your dental supplier to get a quote on this aseptic dental operatory feature).

 

So, the advantages are clear. So is the law. If you have not yet done so, make sure you place a small sharps container and red bag in each of your treatment rooms. The benefits outweigh the risk. Just do it!

 

Written by Jill Obrochta and Heather Whitt of Dental Enhancements