Effective October 1, 2017, all dentists licensed in Tennessee will be subject to a random OSHA inspection. This is part of the Local Emphasis Program.
According to OSHA, they analyzed data collected over a 10-year period. The results indicate that 319 serious hazards were identified with an average of 11.8 per facility. The Local Emphasis Program will focus primarily on exposure to blood and other potentially infectious materials and exposure to hazardous chemicals. Each year, the OSHA area offices will be expected to inspect at least five (5) dental offices and this includes offices with less than ten (10) employees.
If you are selected for an audit, your inspection will also include the following areas:
- Bloodborne Pathogens
- Hazard Communication/GHS
- Personal Protective Equipment
- Nitrous Oxide
- Ionizing Radiation
- Infection Control
Your Work Exposure Control Plan must be up to date and all team members must know how to access it. This is why we are recommending maintaining digital copies of the manual in your system.
OSHA would also review solicitation of input from employees thus the safer device evaluations are critical. These evaluations must be produced at least annually and seek the input of non-managerial employees at risk for bloodborne pathogen transmission. OSHA would evaluate your engineering controls and work practice controls.
Sharps containers must be located as close as possible where sharps are used in each operatory, not hidden in a cabinet.
OSHA would evaluate whether the hepatitis B vaccines are offered in compliance with the Code. They would also review any post exposure documentation to ensure compliance.
Training records would be evaluated to verify compliance. If you attended an OSHA-HIPAA seminar, keep in mind that training must also be provided in-office to provide site specific information.
Your Safety Data Sheets must be in order and containers must be properly labeled according to GHS.
OSHA will also evaluate issues that associate to the General Duty Clause. This includes ergonomics, nitrous oxide, ionizing radiation, tuberculosis, silica, mercury, beryllium, and infection control. They would ascertain whether you have the required posters in place.
In addition to TOSHA’s resources (http://www.tn.gov/workforce/section/tosha), we encourage you to read the Tennessee Dental Association Journal Volume 97-1 2017 which provides an overview of required training, documentation, and policies.
We encourage you to contact our office if you wish to schedule a training and office update. Our goal is to make certain you are “audit ready.” Give us call (931) 232-7738 or email firstname.lastname@example.org.