Provided by Smart Training

A Virginia-based DSO-affiliated practice underwent an unscheduled inspection by Virginia State OSHA (VOSH) in February. (It should be noted that state OSHA departments enforce federal guidelines; and potentially, state-specific regulations.)

During the inspection, 2 out of 58 items were flagged on the industrial hygienists’ “Form 33″—a document used in dental facility inspections. These 58 items contain six subsections, making up a 348-point inspection (unless other items are noted).

The violation of Federal OSHA 1910.1030.F.2; in particular, having insufficient Hep-B vaccination documentation, resulted in a penalty exceeding $6,000.

1910.1030 F2 “Hepatitis B Vaccination” (i-iv):

To address the deficiencies, the practice must adhere to the following subsections:

  • Hepatitis B vaccination shall be made available to ALL employees after they have received training and within 10 working days of initial assignment,
  • The employer shall not make participation in a prescreening program a prerequisite for receiving hepatitis B vaccination,
  • If the employee initially declines hepatitis B vaccination but later, while still covered under the standard, decides to accept the vaccination, the employer shall make available hepatitis B vaccination at that time,
  • The employer shall assure that employees who decline to accept hepatitis B vaccination offered by the employer sign the statement in appendix A.

“ALL” in this context means EVERYONE!

There’s no room for debate: any employee entering the facility faces occupational exposure to bloodborne pathogens, including front office and administrative staff.

It must be emphasized again that there is no leeway here. In case some readers don’t grasp the gravity of the requirement: Smart Training compliance advisors have seen firsthand practices penalized over $6,000 for each bulleted subsection above.

Don’t let this happen to your practice.

If navigating regulatory compliance feels daunting, seek professional guidance to ensure adherence to the standards and be prepared for surprise inspections. Smart Training’s compliance experts offer a complimentary assessment to mitigate liability and safeguard your patients and team.

Inspection Detail | Occupational Safety and Health Administration