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5 Steps Towards OSHA Compliance

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Elizabeth Phillips

Let’s face it: for the healthcare worker in a medical or dental office, the risk of exposure to injury and bloodborne pathogens is great.  There are literally handpieces, scalpels, and needles used daily.  Performing minor surgical procedures, examining wounds, cutting into teeth, or even removing teeth are actual common occurrences!  These things are the stuff of nightmares and horror films for the average person, but for the healthcare worker this is simply routine.   So how does a medical or dental practice go about ensuring the protection of its workers? Enter OSHA.

According to, the goal of the Occupational Safety and Health Act of 1970 (OSHA) is “to ensure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”  


We all want safe work environments.  And depending upon what context you find yourself working in, safety can mean different things.  OSHA regulations are very industry specific.  The Bloodborne Pathogens Standard addresses healthcare workers specifically and is designed to protect at-risk employees from exposure to blood and other potentially infectious materials. Employees and healthcare workers covered by this standard include those who have direct patient/resident contact, draw blood, work with blood and other bodily fluid specimens, and/or handle contaminated equipment.

We asked Angela Simmons, an active member of the Healthcare Compliance Association, about what steps medical and dental practices can take to ensure OSHA compliance.  She gave us the following 5 Steps to take towards OSHA compliance.


5 Steps for OSHA Compliance


Step One: A written Exposure Control Plan


OSHA requires that medical and dental practices have a written plan to address the potential likelihood that an employee is exposed to blood borne pathogens while working with patients.  The plan must be specific to the practice and indicate the process for ensuring that bloodwork for the source patient and exposed employee is obtained. Additionally, the exposed employee must receive a free and confidential medical evaluation (this will generally be a medical doctor at an independent location from the practice).


Step Two: Training


The Bloodborne Pathogen Standard requires that exposed employees are trained within 10 days of hire and, at least, annually.   Because OSHA is about worker safety, this requirement serves as a reminder that there are controls in place to keep the healthcare worker safe and to reduce the likelihood of their exposure to blood borne pathogens through accident or injury.


Step Three: Immunization 


The best defense against disease is immunization.  OSHA requires that employers OFFER the Hepatitis B Vaccine (HBV) series to all anticipated exposed employees within 10 days of hire.  The employee can show proof, accept the series, or decline the series.  The employer must document their effort to provide the series.  Employers cannot require titers before they will provide the HBV series to an exposed employee.  Since the implementation of the HBV series under OSHA the rate of infection among healthcare workers has declined by 98%.


Step Four: Engineering Controls


Engineering controls are devices that are designed to isolate or remove hazards, thereby protecting the healthcare worker against exposure to blood borne pathogens.  Sharps containers are excellent examples of engineering controls.  Sharps containers are designed to be leak proof, spill proof, and puncture resistant.  They should be placed at the point of use to eliminate the transportation of dirty, disposable sharps to reduce the likelihood of injury.  Another important control is the use of safety engineered sharps that are designed to help protect the end user from injury with the use of guards, sliding sheaths or retractable systems.


Step Five: Personal Protective Equipment (PPE)


OSHA requires that employers provide appropriate PPE to employees.  Personal Protective Equipment helps protect employees from exposure to blood and other bodily fluids when working with patients.  Employers must provide the appropriate PPE, ensure employees are trained in how to use their PPE, and ensure that employees wear their PPE appropriately based on the tasks they are performing. Examples of appropriate PPE within a medical or dental environment includes, but is not limited to, glasses, gloves, masks, and jackets.

The implementation of these 5 Steps should help your medical or dental practice to be on its way towards OSHA compliance. To really make sure you keep the nightmares and horror stories at bay, call CentraVance Consulting today to set up your Free Risk Assessment or Bloodborne Pathogen Standard Training today!

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