For a dental practice in Colchester, CT, a seemingly routine day took a surprising turn.
“On or about March 1, 2023,” a complaint (likely anonymous) received by the Occupational Safety and Health Administration (OSHA) triggered a regulatory investigation that unearthed numerous violations.
This is yet another example of letting the camel’s nose under the tent flap, as Smart Training Vice President Lee Slaton terms these incidents. In this case, it seems the entire camel got under: in the initial investigation, 12 serious citations were made and approximately $43,644 in penalties imposed.
The focus of the investigation appears to have been centered on violations of the Bloodborne Pathogens standard 1910.1030(C-G).
The items broken down in the public record state the practice lacked the following mandatory items:
- An annually updated Exposure Control Plan
- Reviews of work and engineering controls
- Feedback solicitation from non-management staff
- Access to Hep-B vaccination, and
- A demonstration of alternative methods of sharps management and exclusion.
As the investigation went deeper, secondary violations were uncovered, including:
- Contaminated laundry receptacles lacking biohazard warnings
- Inadequate personal protective equipment (PPE) for handling such materials
- Inadequate eyewash facilities, based on chemicals on site. (Though details on the present facilities were left out of the report, I assume the ANSI standard was not followed. The standard requires 15 minutes of non-scalding water to be delivered with adequate pressure to each eye simultaneously.)
- An inadequately maintained SDS binder, which was missing several sheets for chemicals in the facility.
This case is still open; and via abatement, the penalties appear to have been reduced to $30,551 (October 16, 2023). You can learn more about this and other cases at OSHA’s website.
How can you improve the safety culture for your team and patients and avoid your own version of a critical incident like the one “on or about March 1, 2023”? Recognizing your workplace might not be adequately equipped to manage an anonymous OSHA complaint is a vital first step. Fortunately, there are seasoned experts available to help you prepare for such scenarios. Smart Training is home to a team of experienced compliance advisors who specialize in guiding practices to protect against regulatory pitfalls. If you’re uncertain about your practice’s regulatory compliance, reach out to Smart Training; their expertise is at your disposal.