Provided by Smart Training

Many dentists are not aware of aspects of OSHA compliance, which leaves them in a precarious situation. If you read our article last month, you know OSHA fines can now soar to over $16,000 per violation; depending on the severity and the entity’s overall level of compliance.

A small dental practice in Connecticut learned this at exorbitant cost when it received a visit from OSHA’s Department of Labor in late 2023 and racked up over $21,000 in serious penalties. This practice is “lucky” the inspection occurred prior to the inflation-adjusted increase for allowable fines.

What were the violations?

Based on the penalties outlined in the inspection report1, it appears the practice experienced either a needlestick or other form of percutaneous injury that triggered the inspection.

Significant penalties were incurred because the practice was not in compliance with mandatory components of the Bloodborne Pathogens Standard. There was:

  • No annually updated Exposure Control Plan with Job Hazard Assessment
  • No documentation of bloodborne pathogens training
  • No documentation of employer-offered Hepatitis-B vaccination
  • No post-exposure evaluation or testing of source patient until after 27 days

This begs the question, did the practice have an exposure control plan in place, should an exposure incident occur? If so, it was clearly not executed. Many practices lack two or three of the components when Smart Training has its initial consultation with the office.

This case may be viewed as an extreme example, but OSHA’s “Violations by Establishment” website offers page after page of similar incidents; which, by the way, are public record.

Why this practice was “lucky.”

In Smart Training’s experience, if one written program is outdated, there’s about a 99% chance all of them are. In this case, the inspector didn’t proceed to inspect the Emergency Action, Hazard Communication, and Respiratory Protection programs.

Additionally, this practice does not appear to be involved in a civil suit, though the risk of this occurring is real.

If you’re feeling overwhelmed, unsure if your team has the required documentation and training, or if there’s an untouched and outdated “OSHA Binder” lurking in your office, it’s a good idea to contact Smart Training. They can provide a comprehensive assessment and guidance to address these and other significant issues before they become costly for your practice.

1Inspection Detail | Occupational Safety and Health Administration