Provided by Smart Training

At the 2024 TDA Meeting in San Antonio in May, we spoke with many attendees and discovered significant gaps in their regulatory compliance.

Following are three examples of common violations—listed under the standard not met. (You can easily find these cited on OSHA’s “Violations by Establishment” webpage.)

You may have systems in place to address the standards, but there could be gaps in your compliance that you’re not aware of. Unfortunately, a lack of awareness won’t be considered an excuse should your practice be surprised with an inspection.

Bloodborne Pathogens

Most people Smart Training representatives spoke with at the Meeting had only partial compliance with the bloodborne pathogens standard.

In March, an Arizona practice was fined $9,488 for a bloodborne pathogens standard violation; specifically, having an unlabeled hamper in the break area containing soiled lab jackets.

29 CFR 1910.1030(d)(4)(iv)(A)(2): Contaminated laundry was not placed and/or transported in bags or containers which were labeled or color-coded in accordance with 29 CFR 1910.1030(g)(1)(i).”

General Provisions and Industry Standards

The same practice was fined an additional $9,488 for not having eyewash stations near corrosive substances, such as Patterson Tartar and Stain Remover and pdCare Surface Wipes.

“29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use.”

Infection Control

Most Meeting attendees Smart Training spoke with had robust infection control systems; however, infection control is a common area for non-compliance.

For example, if you have wrapped cassettes and are not internally verifying sterilization, you’re at high risk for an infection-control breach and possible OSHA citation. Additionally, you’d be out of compliance with CDC’s 2003 “Morbidity and Mortality Weekly Report” (MMWR) guidelines, which states:

“Internal chemical indicators should be used inside each package to ensure the sterilizing agent has penetrated the packaging material and actually reached the instruments inside. A single-parameter internal chemical indicator provides information regarding only one sterilization parameter (e.g., time or temperature). Multiparameter internal chemical indicators are designed to react to >2 parameters (e.g., time and temperature; or time, temperature, and the presence of steam) and can provide a more reliable indication that sterilization conditions have been met.”

Of note, most attendees Smart Training representatives spoke with had inadequate strategies for many of OSHA’s lesser-known general provisions. Again, a lack of awareness won’t be considered an excuse should your practice be found non-compliant.

Concerned about gaps in your compliance? Contact the experts at Smart Training for a free consultation.