What is a Dental OSHA Compliance Manual?
Dental practices must comply with the Occupational Safety and Health Act (OSH Act), a federal law administered by the Occupational Safety and Health Administration (OSHA). OSHA’s function is to ensure employers furnish employees a place of employment that is free from recognized hazards that are causing, or likely to cause, death or serious physical harm to those employees. OSHA enforces its mandate through a series of safety standards.
These standards regulate various types of hazards present in a dental workplace. Such hazards include bloodborne pathogens, hazardous chemicals, and other substances (such as respirable crystalline silica and beryllium). OSHA enforces these standards through investigations and fines.
Traditionally, an OSHA compliance manual for dental offices played a crucial role in dental office OSHA compliance. This manual would contain copies of the regulations and specific procedures employers needed to implement to ensure employee safety under the regulations.
Many dental offices still use a dental OSHA compliance manual. Many others have moved away from a paper manual, and have posted safety standard compliance information online. Regardless of the form the OSHA compliance manual for dental offices takes, it must contain specific content covering specific standards.
The Dental OSHA Compliance Manual: It’s In Your Blood
Dental workers may be exposed to bloodborne pathogens or other potentially infectious materials (OPIM) as they perform work using sharps.
The OSHA bloodborne pathogens standard requires that employers limit employee exposure to bloodborne pathogens. The standard requires dental employers to provide OSHA training to employees so they know how to:
- identify bloodborne pathogens
- institute measures to minimize exposure; and
- use appropriate personal protective equipment
The measures dental employers must use to minimize exposure must be included in a written bloodborne pathogen exposure control plan (ECP). The OSHA compliance manual for a dental office must contain this document, so employees can readily access it for guidance.
Suppose a dental OSHA compliance manual does not contain an ECP, or an employer has not developed one. In that case, the employer faces potential fines should they suffer a bloodborne exposure that causes injury.
The OSHA compliance manual dental ECP component must be written in plain language that employees can understand. Dental practices must also ensure the plan’s effectiveness by making periodic revisions as needed.
For example, the ECP requires that employers attempt to substitute safer methods of working with sharps to reduce the risk of contamination. If an employer introduces a safer method, the employer must include and describe the details of the method in the ECP, and update the OSHA compliance manual by with the new ECP.
The Dental OSHA Compliance Manual: Something’s in the Air
Dental practices and labs, when performing procedures such as making alloys or crowns or performing X-rays, must institute safety measures to minimize employee exposure to hazardous chemical exposures that may result from these activities.
Crown and alloy production release harmful beryllium and respirable crystalline silica dusts into the air. OSHA requires employers to minimize airborne exposure to these substances by setting permissible exposure levels, or PELs, which are the maximum permitted concentrations of these substances.
If beryllium or respirable crystalline silica dust exposure exceeds a certain amount, the employer must implement safety measures to reduce the level to a permissible one. The dental OSHA compliance manual must contain a beryllium and respirable crystalline silica exposure control plan.
These plans must include a description of the:
- tasks in the workplace that involve exposure to the harmful substance (e.g., beryllium or respirable crystalline silica);
- engineering controls, work practices, and respiratory protection the dental employer uses to limit employee exposure to beryllium and respirable crystalline silica; and
- housekeeping measures used to limit employee exposure to beryllium or respirable crystalline silica.
The Dental OSHA Compliance Manual: Is There Anything Else?
An OSHA compliance manual for dental offices must also cover other safety standards. Some safety standards focus on how the practice must respond in an emergency. General emergency response is covered under the emergency action plan standard. Specific details to be covered in an emergency action plan include:
- Procedures for reporting a fire or other emergency
- Procedures for emergency evacuation, including type of evacuation and exit route assignments
- Procedures to be followed by employees who remain to operate critical operations before they evacuate
- Procedures to account for all employees after evacuation
- Procedures to be followed by employees performing rescue or medical duties
- The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan
The OSHA compliance manual for dental must also include a fire prevention plan, as required by the fire prevention standard.
Specific details to be covered in a fire prevention plan include:
- A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard
- Procedures to control accumulations of flammable and combustible waste materials
- Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials
- The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires
- The name or job title of employees responsible for the control of fuel source hazards
Use our OSHA Compliance Checklist for Dental Offices to learn more about your practice’s compliance.
