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Understanding the Primary OSHA Regulations that Apply to Medical and Dental Facilities

 Most of us already know that OSHA plays a major role in setting and enforcing standards that protect employees from all sorts of workplace hazards. In healthcare and dentistry there are several standards that apply and by identifying them hopefully we can help you understand your responsibilities to help maintain a safe workplace.

One of the most obvious OSHA regulations for healthcare and dentistry is the Bloodborne Pathogens Standard (29 CFR 1910.1030). This standard aims to protect employees from health hazards related to exposure to blood and other potentially infectious materials (OPIM). Key components of this standard include:

  • Exposure Control Plan: Employers must develop a written plan outlining protective measures to eliminate or minimize employee exposure to bloodborne pathogens. This plan should be reviewed and updated annually.
  • Universal Precautions: All blood and OPIM should be treated as if they are infectious, regardless of the perceived status of the source.
  • Engineering and Work Practice Controls: Use of devices such as sharps disposal containers and needleless systems, as well as techniques like hand washing and proper handling of needles and other sharps.
  • Personal Protective Equipment (PPE): Provision and use of appropriate PPE, such as gloves, gowns, and face shields, to protect employees from exposure.
  • Training and Hepatitis B Vaccinations: Employers must offer hepatitis B vaccinations to all employees at risk of exposure and provide regular training on bloodborne pathogens.

The Hazard Communication Standard (29 CFR 1910.1200) ensures that employees are informed about the hazards associated with chemicals they may encounter in the workplace. Key requirements include:

  • Chemical Inventory: Maintaining a list of all hazardous chemicals used in the facility.
  • Safety Data Sheets (SDS): Ensuring that SDSs for all hazardous chemicals are readily accessible to employees.
  • Labeling: Proper labeling of all chemical containers with the identity of the hazardous chemical and appropriate hazard warnings.
  • Training: Providing employees with training on the Hazard Communication Standard, the hazards of chemicals in their work area, and protective measures.

OSHA’s Personal Protective Equipment Standard (29 CFR 1910.132) requires employers to assess the workplace to determine if hazards are present that necessitate the use of PPE. If PPE is required, employers must:

 If PPE is required, employers must:

 Provide Appropriate PPE: Supply employees with the necessary PPE at no cost.

  • Training: Ensure that employees are trained on the proper use, maintenance, and disposal of PPE.
  • Maintenance: Ensure that PPE is properly maintained and replaced when necessary.

  The General Duty Clause (Section 5(a)(1) of the OSH Act) requires employers to provide a workplace free from recognized hazards that are causing or are likely to cause death or serious physical harm. This clause serves as a catch-all provision for hazards not specifically addressed by any OSHA standard. Employers must: 

  • Hazard Assessment: Regularly assess the workplace for potential hazards.
  • Mitigation Measures: Implement measures to eliminate or reduce identified hazards.

 OSHA’s Recordkeeping and Reporting requirements (29 CFR 1904) mandate that certain employers maintain records of work-related injuries and illnesses. Key aspects include:

 Sharps Injury Log and Hepatitis B Vaccination documentation. This technically falls under the Bloodborne Pathogen Standard, but documenting both is critical.

  • OSHA 300 Log: Recording work-related injuries and illnesses on the OSHA 300 Log.
  • Severe Injury Reporting: Reporting any work-related fatalities, in-patient hospitalizations, amputations, or losses of an eye to OSHA within specified timeframes.

  By understanding and following these standards, your employers with your help, can protect you from a wide range of hazards, ensure regulatory compliance, and promote a culture of safety within your practice.

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