Top 5 Safety Tips For Medical And Dental Practices

By Robert Box

Medical and dental practices become snagged in OSHA’s inspection net frequently and the reactions from the practices’ office managers are usually that of complete surprise. Many small practices believe they are exempt from OSHA inspections, regulations and standards, so an OSHA Compliance Officer at their door is the last person they would expect. Once inside, OSHA tends to find the same trend of violations from medical and dental practices across the country –the top five of which are listed below.

Wait –Why Is OSHA Here?

Many medical and dental offices mistakenly assume they are fully exempt from complying with OSHA standards and regulations because they have fewer than 11 workers. That’s not the case at all. In fact, all employers in the U.S. have a legal responsibility to provide a safe and healthful workplace, free of recognized hazards. There is an exemption for most employers with fewer than 11 workers, though. 

The exemption is with regard to record-keeping responsibilities. OSHA published a new rule for record-keeping responsibilities that will take full effect in 2017. Smaller employers, including medical and dental offices, still need to comply with Title 29 of the Code of Federal Regulations (29 CFR). While these smaller employers are not included in random inspections from OSHA, a worker complaint to the agency can result in OSHA at your doorstep. Of all reasons for OSHA to appear at your workplace, 26% of the time is due to a complaint from a worker.

The following are frequently found violations found in medical and dental practices:

1. Bloodborne Pathogens Standard (29 CFR 1910.1030)

The number one requested and referenced OSHA standard regarding medical and dental practices pertains to bloodborne pathogens. Basic requirements of this standard include:

• A written exposure control plan, which should be reviewed and updated annually
• Office safety policies that include use of universal precautions
• Implementation of the safe use of needles and other types of sharps
• Hazard control, including engineering, administrative, and personal protective equipment like gloves, face and eye protection, gowns, etc.
• Hepatitis B vaccines provided to exposed workers at no cost
• Provide proper medical treatment in the event of an “exposure incident”
• Use of labels or color-coding for items such as sharps disposal boxes and containers for regulated waste, contaminated laundry, and certain specimens
• Bloodborne Pathogen training administered to workers
• Proper disposal of containment of contaminated waste

2. Hazard Communication (29 CFR 1910.1200)

The updated hazard communication standard, or Globally Harmonized System, is sometimes called the “The worker’s right to understand” standard. It requires worker access to hazard information, including:

• A written hazard communication program
• A list of hazardous chemicals (such as alcohol, disinfectants, anesthetic agents, sterilants, mercury) used or stored in the office
• A copy of the Safety Data Sheet (SDS) for each chemical (obtained from the manufacturer) used or stored in the office
• Appropriate worker training

3. Ionizing Radiation (29 CFR 1910.1096)

For offices that utilize an x-ray machine, the following is required: 

• A survey of the types of radiation used in the office/practice, including x-rays
• Restricted areas designated and labeled (signs) to limit worker exposure
• Workers in restricted areas must wear personal radiation monitors such as film badges or pocket dosimeters

4. Exit Routes (29 CFR Subpart E 1910.35, 1910.36, 1910.37, and 1910.38 and 1910.39)

Many smaller practices may utilize exit pathways or areas directly in front of emergency exit doorways as extra storage space, but this is dangerous and illegal. The basic responsibilities include:

• The number of exit routes should be sufficient for the number of workers in the occupied space
• Exit doorways should be unobstructed, marked and well illuminated
• A diagram of evacuation routes should be posted in a visible location

5. Electrical (Subpart S-Electrical 29 CFR 1010.301 to 29 CFR1910.399)

•  All staff must be properly trained in the use of all electrical equipment
• Equipment must only be used by office staff for the purpose of performing assigned work/tasks
• In the event of malfunction, the equipment must be immediately tagged “Out of Service” (or something similar) to indicate it is not to be used until repaired or replaced
• If flammable gases are used, special wiring may be required along with special equipment installation and use

Also –Don’t Forget…

Every workplace must display the OSHA poster. The poster explains worker rights to a safe workplace and how to file a complaint. The new OSHA poster addresses worker protection from employer retaliation and satisfies OSHA’s requirement to inform workers of the anti-retaliation law.  

Safety First Consulting 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.