OSHA in the Dental Office: Guidance for the Practice Manager

OSHA in the dental office can be a challenging subject to tackle. The Occupational Health and Safety Administration—the agency responsible for setting and enforcing workplace safety rules—has a lot of guidance for specific industries. Unfortunately, the dental field is not one. That does not mean OSHA compliance is optional. It just means that there are no specific guidelines for OSHA in dentistry. You must follow the general duty guideline.

Each employer -- (1) shall furnish to each of his 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; (2) shall comply with occupational safety and health standards promulgated under this Act.

The problem is it is pretty broad;

To adopt OSHA standards in your dental office, you must break it down into individual hazard levels. That means creating guidance for specific tasks, equipment, and chemicals that could put your dental team at risk.

 

Adopting Standards from OSHA in the Dental Office

The straightforward way to start tackling OSHA in the dental office is to examine the first and second clauses of the general duty guideline. The first clause specifies that dental offices need to give their employees a place free from recognized hazards that could hurt them.

“Recognized hazards” is the key term that you want to focus on. You have a duty to identify, warn, and protect your workers from hazards that you know about or should know about. Examples include blood and OPIM from patients, radiation from X-ray equipment, or dangerous chemicals like nitrous oxide, silica dust, and beryllium. The first step to any OSHA program is a thorough audit of your facilities and the everyday tasks of your dental team.

Someone should walk the office from one end to another, looking for potential hazards on the way and taking note of them. They should also follow the patient's journey, from the moment they walk into the waiting room, until after their procedure is done. During that step, you can identify all the hazards specific to performing job duties. Once all the hazards are noted, you must find a way to address them. The CDC does an excellent job of explaining this with its hierarchy of controls.

The hierarchy moves from the most effective means of hazard management (removing hazardous items) to the least effective (using equipment to protect against exposure). That is the same way you should move when addressing hazards in your dental office. If the hazardous item cannot be eliminated, seek out substitutions. If you can't substitute it, engineer it in a way that it is safer, and so on.

Needles are a notable example of this. You can't eliminate them, nor can you substitute them for something less invasive. but there are ways to make them safer through engineering controls. Caps, safer storage, and closed disposal boxes are all ways of engineering around the hazard. Training workers on safe handling covers administrative controls, while the PPE segment is addressed by the gloves they wear when using needles. These three layers mitigate the risk that needles present.

That hierarchy is a terrific way to manage the hazards in your office and manage the first part of the general duty clause. The second part is a bit more complex because in that single sentence lies the responsibility for hundreds of different acts and regulations.

 

Knowing What Guidelines to Follow

As you work to implement OSHA in your dental office, you are going to run into a lot of overlap from another agency; the Centers for Disease Control and Prevention (CDC). OSHA is about controlling the hazards your workers face; the CDC controls the hazards the public faces. Because your workers are also part of the public and interact with them regularly, many of the regulations set by OSHA follow CDC guidelines.

The specific hazards in your office will be defined by your audit, as well as hazards that are inherent to dentistry. Regulations and guidance from OSHA/the CDC that may affect dental offices include:

 

OSHA	CDC
Beryllium exposure risk Bloodborne pathogens and infection controls Ergonomics Ionizing radiation (medical x-rays) Personal protective equipment Mercury exposure risk Silica dust exposure Waste anesthetic gases	Infection Control Guidance for Healthcare Professionals about Coronavirus Reprocessing Dental Handpieces Immunization of Health-Care Personnel Screening and Evaluating Safer Dental Devices

 

Both agencies regularly complete updates of their programs to improve safety for workers and the public. The above regulations, rules, and guidance sheets represent only a small fraction of the mandates that could affect your office. That is why it is always wise to work with a third-party consultant for managing your dental office's OSHA needs.

The best guidance for managing OSHA in the dental office is to collaborate with an expert. Within the general duty clause are a lot of responsibilities that might not be obvious. A third-party evaluation can give transparency to the hazards in your dental office so you can address them and protect workers.

OSHA can be a difficult topic for practice managers to tackle when they are new to the job. Regular training both for them and the people that work under them will help ensure that they are always in compliance with all the rules that affect dentistry.