OSHA Compliance For Medical & Dental Practices

This article is offered to assist medical and dental practices in knowing the basic areas in need of OSHA compliance based on most frequently found hazards, and where to find resources for solutions. 

by, Robert Box

Whether a medical or dental practice has one employee or one-hundred employees, the employer has an obligation to provide a place of employment free from recognized hazards that are causing or likely to cause death or serious physical harm to its workers.

However, many medical and dental practices do not have a person to specifically handle safety, health and OSHA compliance responsibilities.  Safety-related responsibilities are oftentimes “added on” to responsibilities of an office manager, human resources manager or assistant.

This article is offered to assist medical and dental practices in knowing the basic areas in need of OSHA compliance based on most frequently found hazards, and where to find resources for solutions.  However, this is not a comprehensive list of all OSHA compliance requirements that may apply, depending on specifics of the practice.  The complete documentation of regulations can be found in Title 29 of the Code of Federal Regulations (29 CFR 1910, General Industry Standards).

Bloodborne Pathogens Standard

The bloodborne pathogens standard can be found in 29 CFR 1910.1030.  The standard for bloodborne pathogens is the most frequently referenced standard for citations related to medical and dental practices.  Basic requirements of this standard include:

• A written bloodborne pathogens exposure control plan, which must be updated annually.
• Use of universal precautions.
• Use safe disposal of safer needles and sharps.
• Primarily using engineering and administrative solutions to control hazards to workers before requiring and issuing personal protective equipment (PPE) to control those hazards.
• Hepatitis B vaccination provided to exposed workers at no cost to them.
• Free medical examination following a possible contamination exposure incident.
• Color-coding and labeling for sharps disposal boxes, containers for regulated waste, contaminated laundry and some specimen materials.
• Documented worker training.
• Containment of regulated waste materials.

Hazard Communication Standard

The hazard communication standard can be found in 29 CFR 1910.1200.  In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. Basic requirements for employers include:

• A written hazard communication (HAZCOM) program.
• A list of hazardous chemicals used or stored in the office (e.g., alcohol, disinfectants, anesthetics, sterilants, mercury and the like).
• A copy of Safety Data Sheets (SDS) for each chemical used or stored in the office.  SDSs can be obtained from the chemical/product manufacturer.
• Proper container labeling.  Secondary containers must be labeled properly when not in immediate use.  Labels must include a signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
• Documented worker training.

Ionizing Radiation Standard

The ionizing radiation standard can be found in 29 CFR 1910.1096.  For facilities that have an X-Ray machine, this standard requires the following:

• A survey of the types of radiation used in the facility, including X-Rays.
• Restricted areas to limit exposures to workers.
• Provisions for workers to wear personal radiation monitors in restricted areas.
• Special equipment and some rooms may require caution signage.

Means of Egress (Exit Routes) Standards

Means of egress standards can be found in 29 CFR 1910.35, 29 CFR 1910.36, 29 CFR 1910.37, 29 CFR 1910.38, and 29 CFR 1910.39.  These standards involve requirements for safe and continuously accessible building exits in case of fire or other emergency.  It is necessary to become familiar with the entirety of these standards because they provide specifics regarding signage, aisle widths, lighting during emergencies, and the like.  Basic employer responsibilities include:

• The number of exits from the workplace is sufficient for the number of workers in any occupied space.
• Exit routes are properly marked, and non-exit routes are marked, “Not An Exit.”
• Except for specific exceptions, at least two exit routes must be available to workers.
• A posted diagram of evacuation routes must be posted in a visible location.
• Documented worker training and annual drills.

Electrical Standards

Electrical standards can be found in 29 CFR 1910.301 through 29 CFR 1910.399, but most applicable standards can be found in 29 CFR 1910.303, 29 CFR 1910.304, and 29 CFR 1910.305.  Basic employer requirements include:

• Assuring electrical systems, boxes, outlets, panels, etc. are properly installed, grounded and enclosed.
• Extension cords are inspected prior to use and are not used if defects are found.
• Extension cords are not run through walls, windows, doors or otherwise are used as a substitution for permanent wiring.
• Extension cords and power strips should not be affixed to the structure or furniture such that a tool is required to move/remove the cord.
• OSHA can reference other standards like National Fire Protection Association (NFPA) or Underwriters Laboratories (UL).  For example, UL 2001 says extension cords cannot be plugged into one another (daisy-chain), and OSHA frequently cites this deficiency.
• Breaker panels and electrical disconnects cannot be blocked or obstructed.
• If flammable gases are utilized in a work area, special wiring and equipment installation may be required.

OSHA Poster

The standard that refers to the requirement of displaying the OSHA poster can be found in 29 CFR 1903.  Every employer must prominently display the OSHA poster.  The poster has information regarding worker rights for a safe workplace and how to file a complaint, if necessary.  The newest version of the poster says workers are free to report injuries and illnesses to employers without fear of retaliation.

The poster is free and must be placed where workers will see it.  A copy can be downloaded here.

Safety First Consulting is a contributor of SM Corridor News and helps businesses identify OSHA compliance issues in their workplaces, manage their safety programs, and we become accountable for the results. In addition to offering custom written safety programs for companies, Safety First Consulting provides required safety training, industrial hygiene sampling, noise sampling, and workplace inspections. You can read more from Robert Box under Business.