This article outlines Occupational Safety and Health Administration (OSHA) guidelines for maintaining a safe dental practice workplace and covers requirements, such as education and protection for dental health care personnel. OSHA regulations aim to reduce exposure to blood-borne pathogens. Environmental infection control in dental offices and operatories is the goal of enforcement of OSHA codes of practice. Universal precautions reduce the risk for infectious disease. OSHA has a mandate to protect workers in the United States from potential workplace injuries. OSHA standards are available through online and print publications and owners of dental practices must meet OSHA standards for the workplace.
In 1970 more than 14,000 accidental deaths occurred in the workplace in the United States . In an effort to reduce the number of injuries and deaths among United States workers, Congress passed legislation, termed the Occupational Safety and Health Act, that year establishing new workplace safety laws. The Occupational Safety and Health Administration (OSHA), created as a division of the Department of Labor, enacts workplace safety standards and oversees these standards. OSHA rules apply to dental clinics and all other privately owned places of work in the United States. Compliance with OSHA guidelines is mandatory for all owners of dental practices that employ dental personnel. Federal law requires OSHA annual training sessions on current OSHA regulations for all dental offices. Fines and penalties are imposed on employers who fail to meet OSHA standards. Dental practice owners are given an opportunity to redress shortfalls in workplace safety protocols and have the right to challenge any citations deemed unfair. The OSHA regulations are readily available and clearly stated in print and on-line formats. The American Dental Association (ADA) also publishes updated OSHA compliance standards for dental offices, available since 2003 through a link on the ADA Web site ( http://www.osha.gov/dcsp/compliance_assistance/quickstarts/health_care.html ) . In dental clinics and in all places where dentists practice, OSHA protections are especially important to provide safeguards against biologic pathogen transmission and physical injuries, including needlesticks.
OSHA broadened its protections for workers in 1980 to reduce chemical and biologic risks to workers . Employees, protected under OSHA regulations from exposure to such risks, cannot lose employment for calling attention to workplace hazards. As a result of OSHA rules, the number of workplace deaths fell to fewer than 6000 by 2006, less than half of what it was in 1970 . OSHA has helped reduce workplace fatalities by more than 60% and occupational injury and illness rates by 40% . In two of the historically most dangerous industries, agriculture and construction, workplace injuries and deaths have been reduced dramatically . In contrast, as a result of the increase in the number of health care workers, the number of workplace injuries for dentists are increasing . The health care profession (with more than 12 millions workers) is the second fastest growing sector of the United States economy, and absolute numbers of injuries to health care workers continue to rise . Injuries common to health care personnel include occupational hazards (such as needlestick injuries), exposure to blood-borne pathogens, back injuries, and workplace violence. Disability insurers report that one in three general dentists go on disability at some point during their careers. The regulations of OSHA are great in scope and also specific in areas, such as proper sterilization technique and protection from needlestick injuries. OSHA offices are located in every state in the United States and officials from OSHA monitor workplace safety through unannounced inspections. Certain states have OSHA programs with requirements that are more strict than federal OSHA requirements. Federal, state, and local OSHA officials issue citations and penalties to dental practices not in compliance with current OSHA regulations.
The Occupational Safety and Health Administration mandate
The OSHA mission for nearly 4 decades has been to ensure the safety and health of workers in the United States. OSHA standards are set and enforced through random, unannounced inspections of dental practices throughout the United States. OSHA workers, however, also provide training and education and partner with other associations, such as the ADA and the National Institute for Occupational Safety and Health (NIOSH) in an effort to improve workplace safety and the health of dental care practitioners and their staff. All workers in the dental field are covered by federal OSHA regulations or through one of the 26 OSHA-approved state-run programs. Some states, such as Connecticut, New Jersey, and New York, and the Virgin Islands have OSHA programs that cover state and local government dental practices only; federal OSHA rules apply to all private practices . OSHA standards apply to dental practices in which the owner of a practice has one or more employees.
Occupational Safety and Health Administration standards
The general aim of OSHA standards is to maintain conditions and practices that protect dentists and auxiliary dental personnel from hazards in the patient care environment. The OSHA standards were established to promote workplace safety and are enforced through inspections, citations, and financial penalties. Through a combination of standards for safety equipment and workplace practices, OSHA aims to reduce risks to workers, including the risk for transmission of blood-borne illnesses. Practice owners and their employees must be familiar with and comply with OSHA standards and have personal protective equipment available for use in dental practices to promote safety and health for employees and patients.
Inspectors from OSHA may come to any health care facility or hospital in the United States and issue citations for improper infection control, construction safety, or other issues; in the past few years, OSHA citations have risen 32% . The financial penalties for infractions that have put workers at risk have risen 75% . The onus is on employers to understand the responsibilities outlined by OSHA and to comply with the government agency’s standards. A poster advising dentists and dental auxiliary staff of job safety and health protection must be posted in dental offices. Posters 3165 in English and 3167 in Spanish are available on-line at http://www.osha.gov/Publications/osha3165.pdf or http://www.osha.gov/Publications/osha3167.pdf . Current OSHA standards are laid out clearly in publications available from OSHA on-line at www.osha.gov and through the mail, and OSHA established a toll-free call center telephone number in the early 1990s at (800) 321-OSHA (6742) for further assistance and incident reporting. The complete text of OSHA regulations applying to medical and dental offices may be found listed as Code 29 of the Code of Federal Regulations.
OSHA has a dental practice section on its Web site at www.osha.gov/SLTC/dentistry/standards.html . Although there are no specific OSHA standards for dentistry, there are many areas where general OSHA standards are particularly important ( Table 1 ). Exposure to biologic, chemical, environmental, physical, and psychologic hazards are addressed in OSHA regulations. The OSHA Standard Industrial Classification system for general dentistry is Code 8021 and for dental laboratories, Code 8072 . Where no specific standard for a given workplace condition in dental practice exists, the OSHA General Duty Clause applies. The Clause states, all employers “shall furnish… a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to their employees” . State OSHA regulations are as demanding as the federal standards. All dental offices must comply with standards specific to the dental profession included in Code 8021.
| 29 CFR 1910.1030 | Blood-borne pathogens |
| 29 CFR 1910.1200 | Hazard communication |
| 29 CFR 1910.1450 | Occupational exposure to hazards |
| 29 CFR 1910.151 | Medical services and first aid |
| 29 CFR 1910.134 | Respiratory protection |
| 29 CFR 1910.132 | Personal protective equipment |
| 29 CFR 1910.148 | Formaldehyde |
| 29 CFR 1910.157 | Portable fire extinguishers |
| 29 CFR 1910.105 | Nitrous oxide |
Occupational Safety and Health Administration standards
The general aim of OSHA standards is to maintain conditions and practices that protect dentists and auxiliary dental personnel from hazards in the patient care environment. The OSHA standards were established to promote workplace safety and are enforced through inspections, citations, and financial penalties. Through a combination of standards for safety equipment and workplace practices, OSHA aims to reduce risks to workers, including the risk for transmission of blood-borne illnesses. Practice owners and their employees must be familiar with and comply with OSHA standards and have personal protective equipment available for use in dental practices to promote safety and health for employees and patients.
Inspectors from OSHA may come to any health care facility or hospital in the United States and issue citations for improper infection control, construction safety, or other issues; in the past few years, OSHA citations have risen 32% . The financial penalties for infractions that have put workers at risk have risen 75% . The onus is on employers to understand the responsibilities outlined by OSHA and to comply with the government agency’s standards. A poster advising dentists and dental auxiliary staff of job safety and health protection must be posted in dental offices. Posters 3165 in English and 3167 in Spanish are available on-line at http://www.osha.gov/Publications/osha3165.pdf or http://www.osha.gov/Publications/osha3167.pdf . Current OSHA standards are laid out clearly in publications available from OSHA on-line at www.osha.gov and through the mail, and OSHA established a toll-free call center telephone number in the early 1990s at (800) 321-OSHA (6742) for further assistance and incident reporting. The complete text of OSHA regulations applying to medical and dental offices may be found listed as Code 29 of the Code of Federal Regulations.
OSHA has a dental practice section on its Web site at www.osha.gov/SLTC/dentistry/standards.html . Although there are no specific OSHA standards for dentistry, there are many areas where general OSHA standards are particularly important ( Table 1 ). Exposure to biologic, chemical, environmental, physical, and psychologic hazards are addressed in OSHA regulations. The OSHA Standard Industrial Classification system for general dentistry is Code 8021 and for dental laboratories, Code 8072 . Where no specific standard for a given workplace condition in dental practice exists, the OSHA General Duty Clause applies. The Clause states, all employers “shall furnish… a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to their employees” . State OSHA regulations are as demanding as the federal standards. All dental offices must comply with standards specific to the dental profession included in Code 8021.
| 29 CFR 1910.1030 | Blood-borne pathogens |
| 29 CFR 1910.1200 | Hazard communication |
| 29 CFR 1910.1450 | Occupational exposure to hazards |
| 29 CFR 1910.151 | Medical services and first aid |
| 29 CFR 1910.134 | Respiratory protection |
| 29 CFR 1910.132 | Personal protective equipment |
| 29 CFR 1910.148 | Formaldehyde |
| 29 CFR 1910.157 | Portable fire extinguishers |
| 29 CFR 1910.105 | Nitrous oxide |
Universal precautions
OSHA regulations stress the implementation of universal precautions in clinics, operatories, and surgical suite settings. The workplace for oral surgeons, general dentists, and staff may contain many physical dangers. The possibility of exposure to pathogens through contact with patients exists with each patient contact. OSHA has established safety standards regarding blood-borne pathogens to protect against infection. The standards require an exposure plan, annually updated, which includes quick and accurate methods for the determination for an exposure. Lists of all employment activities in which there is increased risk for exposure to infectious materials also must be in place . Paramount among the universal precautions is proper handwashing by health care workers. Employers are required by OSHA to provide employees with handwashing facilities or “where not possible, an antiseptic rinse or cleanser must be provided as a temporary means of hand sanitation” . Effective antibacterial hand cleansers are available that may substitute for handwashing with soap and water. According to the OSHA standards, these hand sanitizers must be readily available, meaning that employees should not have to leave an examination room or operatory to obtain them.
When contact with potentially infectious materials, such as blood, occurs on keratinized skin, OSHA standards require immediate and thorough washing of the affected skin surface. When exposure has occurred to mucous membranes or eyes of the health care worker, OSHA mandates flushing the surfaces with water . Universal precautions help minimize the risks of known methods of disease transmission. The eyes, mucous membranes of the nose and mouth, and areas of the hands that are not intact skin, as are present after a cut, are vulnerable areas for oral surgeons and other health care workers. Thus, eye protection, masks, and gloves have become standard attire while providing care where pathogen-containing fluids may be present. Eye and face protection meet requirements specified by the American National Standards Institute (ANSI) system.
Table 2 summarizes OSHA regulations for general practice offices and the timeline for implementation OSHA requirements.
| Occupational Safety and Health Administration regulation | Timeline | Requirement/evaluation activity |
|---|---|---|
| Employee OSHA training | Annual | Employers are required to annually review all OSHA guidelines with employees and educate regarding updated infection control standards |
| Immunization programs | Year round | Availability of hepatitis B vaccination; employees who refuse must be given a declination statement. Annual review of personnel records to ensure up-to-date immunizations |
| Blood-borne pathogen exposure management | Year round |
|
| Workplace controls for percutaneous needle injuries | Year round | Disposable syringes and needles with safeguard closures and easily accessible sharps containers |
| Antiseptic rinses and cleansers | Year round | Availability of hand rinse and cleansers. Observe and document appropriate handwashing. |
| Evaluation and implementation of safer medical devices | Annual | Annual review of exposure control plan and implementation of newer and safer medical devices |
| Personal protective equipment | Year round | Protective eyewear, masks, and face shields must be available to the clinician during any procedure in which aerosol or airborne pathogens may be present |
| Proper handling and disposal of medical waste | Year round | Observe the safe disposal of regulated and nonregulated medical waste and appropriate preventive measures in place should hazardous situations occur |
| Health care–associated infections | Year round | Assess the circumstances resulting in a suspected transmission from patient to practitioner or vice versa and implement steps to reduce exposure risks |
Personal protective equipment
OSHA has the authority to enforce the ANSI standards, and all safety glasses goggles and face shields worn by employees under OSHA jurisdiction must meet the Z87.1 standard. The ANSI Z87.1 standards enforced by OSHA include mandatory requirements for design, construction, and testing of protective eyewear. The eyewear standards include the following minimum requirements: protective eyewear must protect against the hazards for which they were designed and be reasonably comfortable to allow prolonged use but fit securely without interfering with movement or vision. The standards mandate that the eyewear be capable of disinfection and be easily cleansable. Only eyewear that has been tested and shown to prevent against pathogen transmission and offer impact resistance may be marked “Z87” meaning that the construction meets Z87.1-1979 standards . Secondary protectors, including face shields, may be used as an adjunct to the use of protective eyewear. OSHA regulations mandate that primary ANSI Z87.1 eye protection “must be provided to all employees.” OSHA standards also require that employers ensure that “each affected employee uses appropriate eye or face protection when exposed to hazards” . The hazards outlined include airborne particles, projectiles, vapors, and harmful light. When a wearer of protective eyewear must use prescription lenses, OSHA requires that the provided eyewear incorporate the prescription lenses into the design or allow for wearing the prescription lenses under the eyewear.
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