Knock, Knock. It’s OSHA At Your Dental Office!
By: Gary Iocco
OSHA is at your dental office for an inspection, what do you do?
Front Office says that OSHA is here for a random inspection and your schedule is full. What do you do?
Technically, you may refuse the inspector entry, in which case they will most likely come back with a search warrant. So, that may not be your best bet.
I have been through over fifteen OSHA inspections, some random and some where I have called OSHA in to inspect our facilities.
My advice is to greet the inspector, explain your schedule and have your office manager or another front desk team member handle the inspection.
What are some of the things that the inspector will ask for of you?
- Your bloodborne pathogen (BBP) training records for your staff. OSHA requires his training on an annual basis. There are many online webinars available. You can also ask your laboratory if they offer that service.
- Inspectors will want to see your infection control procedure and your hazard communication plan. Are your Safety Data Sheets (SDS) accessible during business hours? Are they up to date? Do all staff know where they are stored? It is very important to have up to date Hepatitis B immunization records, and by law you need to keep those records for thirty years. They will also ask to see your OSHA Form 300 and 301, injury reports.
- They will ask about your PPE, Personal Protection Equipment as well. Are all staff properly trained on what PPE they need to use and is that PPE in good working order? Do you have an approved eye wash station?
- Inspectors will look at equipment. They will test some electrical equipment to make sure it is properly grounded, check any safety features on the equipment and make sure it is in working order. Are all GFCI outlets in working order? Has Form 300 been posted in the office?
- The Inspector may talk to one or all of your staff so you may need to provide them with an area to interview staff. Some of the questions they may ask your staff might include: When was your last BBP training? Where do you meet in case of a fire? Are you provided with PPE?
Upon conclusion, the inspector will have an exit interview with you. I suggest you speak to the inspector. If there are any violations they will notify you and inform you of any fines. They will also give you a time line for payment of the fines and repairing the violations.
This is not the final report, they will meet with you again and go over their final report, which will outline any and all violations, fines and time line to correct those violations.
Just know that you can negotiate down any fines.
There are many things that inspectors will look at in your office, every inspector seems to have their favorites. Remember that these inspectors are responsible for inspecting many different types of professions and may have done very few to no dental offices. Work with them in a partnership as opposed to an adversarial relationship.
I recommend to our dental clients that they call the safety division of OSHA . They will come out and do an inspection for free, unless you are in Illinois. Illinois informed us that due to State budget they will not do a safety visit. If you have any violations, you will need to correct the violations but you will not be assessed a fine.
Stay safe, call me at 651-438-1191 if you have any questions.
Chairman of the Board
Apex Dental Laboratory Group
Gary Iocco, President of Apex, is a very familiar and recognizable person in the dental laboratory industry. Prior to forming Apex, Gary owned his laboratory, Dimension Dental Design in Hastings, MN for over 30 years. During that time, he acquired and integrated two laboratories into his lab. More visibly, Gary is the Past President of the NADL, Past President of the Midwest Dental Lab Association, and he currently serves as a Trustee on the Foundation for Dental Laboratory Technology (FDLT) and Co-Chair of the NADL’s “What’s In Your Mouth” public relations campaign. In 2016, Gary received the NADL’s Hall of Fame Award, the Association’s highest honor, for his contributions to the industry.