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    OSHA violations that you’re making – and don’t even realize

    While dental practices do their best to stay in OSHA’s good graces, these are some common mistakes that offices can make.


    You don’t have an exposure plan

    The aphorism, “Failing to plan is planning to fail,” is especially relevant when it comes to preparing for an accidental exposure. That is, practices must have a plan in place should an employee accidentally become exposed. And each plan must be specific to the office.

    “Does the office have a written Exposure Control Plan (ECP)?” Daw asks. “Some have a fill-in-the-blank version of this; however, I’ve worked with practices that have told me they were cited because their plan was lacking. And almost all offices have no clue what this is. I recommend each office have one that is detailed and specific to their practice and then share this with the team.”

    ECPs are especially important as needlesticks are concerned.

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    “One of the reasons I think OSHA spends any time in dentistry at all is because needlestick accidents happen,” Canham observes. “A lot of dental practices don’t realize that they need to have an emergency action plan that covers how to handle an exposure incident. The emergency action plan is a step-by-step plan that every team member is acquainted with. It’s just like CPR. You know how to perform CPR step by step, so if a patient stopped breathing, you would know exactly what to do step by step to keep them alive with chest compressions and rescue breathing.

    “Just like regular CPR training, having a current and customized Exposure Incident Protocol lessens the panic and confusion should an incident occur,” she continues. “Employers and the team will know exactly what to do step by step, from First Aid to evaluating the source to what documentation is required to what health care facility to go to.”

    Accidental exposures are, happily, few and far between. Practices may not immediately know what to do should something bad happen.

    “Accidents happen, and because a lot of the dental practices have not conducted the OSHA bloodborne pathogen training, they have not considered what they’re going to do in the event of an exposure incident,” Canham says. “This means the employer has to spend a lot of time trying to figure out, ‘What hospital or healthcare provider do I need to send my employee to?’ ‘What kind of questions do I have to ask the patient, and do I really have to ask the patient questions about their hepatitis or HIV status?’ ‘What forms do we have to fill out?’ and ‘Do I have to call my workers’ compensation carrier?’ Meanwhile, the employee who has been stuck with the instrument or splashed to their eyes nose or mouth with blood or bodily fluid has to wait to be evaluated. Every hour that goes by increases the risk for infection transmission to occur.

    “Without an exposure protocol in place panic, chaos and unnecessary delays occur,” Canham says. “It doesn’t need to take two hours from the time somebody says, ‘Ouch, I just got poked,’ to the time that they are in front of the healthcare evaluator receiving the proper consultation and potentially medication to prevent infection. It can take 10 minutes from the time the ‘ouch’ happens to the time the employee is on their way to the medical evaluator, if they have prepared an emergency action plan for exposure incidents in advance.”

    Daw says information to have in the exposure control plan should include the following:

    • Determination of employee exposure

    • Implementation of various methods of exposure control, including:

      • Universal precautions

      • Engineering and work practice controls

      • Personal protective equipment

      • Housekeeping

    • Hepatitis B vaccination

    • Post-exposure evaluation and follow-up

    • Communication of hazards to employees and training

    • Recordkeeping

    • Procedures for evaluating circumstances surrounding an exposure incident

    Related reading: How to prevent cross-contamination in the dental office

    The plan doesn’t end there though. It should also include information on what to do after the initial incident.

    “The office should have a detailed process for post-exposures, including evaluation and follow-up,” Daw says. “This is part of the ECP but deserves some extra attention because it is often missed and misunderstood. It should be so detailed that a non-clinician should be able to read through and understand the steps in the post-exposure protocol. Some questions to ask: Do I have an incident form? What am I going to say to the source individual? Where am I going to send them for bloodwork? What if the employee or patient decline to be tested, then what? What happens to the results? When do I send the employee back for follow-up?

    “One of the ways I ensure this protocol is properly vetted is to have a front desk person with absolutely no patient contact review this document,” she continues. “If they have additional questions, I may instruct the office to address and include it in the ECP. Unfortunately, few offices have what I would consider a robust process that makes complete sense. And sometimes offices don’t realize their process is lacking until they have an exposure and find their current document is insufficient. An exposure can already be an angst-filled experience. Having an ECP will prevent an OSHA citation. Having an ECP that is detailed and thorough will alleviate the anxiety that comes with an exposure incident.”

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    Robert Elsenpeter
    Robert Elsenpeter is a freelance writer and frequent contributor to Dental Products Report and Digital Esthetics. He is also the author ...


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