As a Compliance Consultant focusing on providing dental practices with the most current information and training on OSHA and dental infection control, I often get asked the same questions many times over: “Do we really have to do OSHA training? Is it required, or just a good idea?”
First, let’s take a step back and review a couple of core premises. The Occupational Safety and Health Act was signed into law on Dec. 29, 1970 by President Richard M. Nixon. Congress then established the Occupational Safety and Health Administration (OSHA), which sets and enforces protective workplace safety and health standards. OSHA’s mission 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. As a part of the US Department of Labor, the OSHA directives are law, which require employers to provide their employees with working conditions that are free of known dangers and hazards. So, the short answer is, yes – training is mandated and a requirement under OSHA, set by the US Department of Labor, thus federal law.
Although general safety training on topics such as emergency evacuation, fire safety and medical emergencies is essential in a dental practice, one of the main requirements is compliance to the Bloodborne Pathogens Standard (29 CFR 1910.1030). The standard provides regulations for employers to ensure team members have a safe workplace while performing their responsibilities surrounding the delivery of dental care. The only way dental team members can comply is by acquiring the knowledge and understanding the rationale for compliance. So, what are the training requirements of the Bloodborne Pathogens Standard?
Section 1910.1030(g)(2) of the Bloodborne Pathogens Standard addresses the specifics of Information and Training, beginning with an overall statement: “the employer shall train each employee with occupational exposure in accordance with the requirements of this section. Such training must be provided at no cost to the employee and during working hours. The employer shall institute a training program and ensure employee participation in the program.”
The Standard also addresses when and how frequently training must be completed, stating training shall be provided as follows: 1) at the time of initial assignment to tasks where occupational exposure may take place; 2) at least annually thereafter; and 3) annual training for all employees shall be provided within one year of their previous training. This means that if a practice schedules their annual OSHA training in August – it must be completed in August each year.
The Standard provides a comprehensive list of subject matter that must be covered in an annual training session and also states, “material appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used’, thus the training content must be understandable to all dental team members. Effective training sessions also include engagement of team members, and here the Standard states, “training must allow for an opportunity for interactive questions and answers with the person conducting the training session.” Lastly, the Standard is clear on who should provide the training, by stating, “the person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.” Some practices are more comfortable bringing in an external expert; others will have team members that are interested, dedicated and committed to carrying out the role of the safety coordinator.
Annual OSHA training must be a priority in the dental practice each year and is mandated by OSHA as federal law. Safety for all dental team members must be taken seriously as a strategy to reduce occupational risk of injury, illness and disease transmission in the dental workplace.
Dr. Katherine Schrubbe, RDH, BS, MEd, PhD, is an independent compliance consultant with expertise in OSHA, dental infection control, quality assurance and risk management. She is an invited speaker for continuing education and training programs for local and national dental organizations, schools of dentistry and private dental groups. She has held positions in corporate as well as academic dentistry and continues to contribute to the scientific literature. Dr. Schrubbe can be reached at [email protected].
