OSHA Compliance for Dental Offices
OSHA compliance for dental offices most often consists of compliance with all applicable common OSHA standards and compliance with any further OSHA standards specifically relevant to the business and the nature of services provided. Common OSHA standards for dental offices include:
- 22 General Requirements
- 25 Stairways
- 35 Means of Egress
- 38 Emergency Action Plan
- 95 Noise Exposure
- 1910 Subpart H Hazardous Materials
- 1910 Subpart I Personal Protective Equipment
- 1910 Subpart J General Environmental Controls
- 151 Medical and First Aid
- 1910 Subpart L Fire Protection
- 1910 Subpart O Machinery and Machine Guarding
- 303 General Electrical Requirements
- 1096 Ionization Radiation
- 1200 Hazard Communication
- 1910 Subpart Z Toxic and Hazardous Substances
- 29 USC 654 OSHA General Duty Clause
- 29 CFR 1904 OSHA Reporting Requirements
Although there are no specific OSHA standards for dental offices, dental office employers with one or more employees must comply with the Occupational Safety and Health Act.
The Act requires each employer: (1) to furnish each of his/her employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees (the General Duty clause); and (2) to comply with the applicable occupational safety and health standards promulgated under the Act.
The Challenge of OSHA Compliance for Dental Offices
The challenge of OSHA compliance for dental offices is working out which OSHA standards for dental offices apply, and which do not. For example, under the “Hazardous Substances” standards, most dentists will have to comply with the “Bloodborne Pathogens” standard, but some will also have to comply with the “Beryllium”, “Crystalline Silica”, and “Nitrous Oxide” standards.
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It can also be a challenge to determine who is responsible for OSHA compliance in shared buildings. For example, while it might be simple to dismiss the “Stairways” standard if a dental office is on the ground floor of a shared building, it may be more complicated to establish responsibility for compliance with the “Means of Egress” standard in a multi-tenanted building.
Complying with the OSHA General Duty Clause
Complying with the OSHA General Duty clause can also be a challenge of OSHA compliance for dental offices due to the issue of ergonomics. Ergonomics is a hot topic in dentistry due to the positions dental practitioners and assistants adopt during treatment and the potential for work-related musculoskeletal disorders – one of the most common causes of injury in dentistry.
In 2000, OSHA published an ergonomics standard, but this was subsequently repealed by a Senate Resolution due to the cost of compliance and pushback from workers’ compensation insurance companies. OSHA subsequently published guidance on preventing musculoskeletal disorders in the workplace which – although not mandatory – can be enforced under the General Duty clause.
Complying with Recordkeeping & Training Requirements
There are few recordkeeping requirements to comply with due to dental offices being a partially exempt low-hazard industry. Therefore, although it is not necessary to maintain OSHA 300 and 301 logs or submit Form 300A annually, it is necessary to record and report any workplace incident that results in an employee fatality, in-patient hospitalization, amputation, or loss of an eye.
The OSHA training requirements vary by standard. Some standards (i.e., the “Personal Protective Equipment” standard) require that employees are trained in how to use the equipment the first time it is provided for them. Other standards (i.e., the “Bloodborne Pathogens” standard require annual training. Note: annual training on some standards may be required by other agencies. For example, annual emergency action plan training is a condition of participation in Medicare.
Conclusion: Help with OSHA Compliance for Dental Offices
There are multiple sources where employers can get help with OSHA compliance for dental offices. A good place to start if your current level of information is limited is our OSHA compliance checklist which provides further information about the Occupational Safety and Health Act and general compliance information for organizations in the healthcare industry.
Thereafter, dental offices can obtain more specific help from OSHA’s “Quick Start Assistant” or from a professional compliance advisor. Finally, OSHA compliance for dental offices is not something that can be ignored. Penalties can be issued by OSHA inspectors when employers “should have known” about the OSHA compliance requirements.
