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Paula ThomasPaula Thomas is authorized by the U.S. Department of Labor, Occupational Safety and Health Administration to teach the 10 and 30-hour General Industry Training. She is the author of KEEPING IN COMPLIANCE, The Dentist's Complete Guide to OSHA and Other Regulatory Bodies. More than 500 dentists currently use her compliance program. In addition, Ms. Thomas is an OSHA Consultant and the Marketing Director for Thomas & Fees, a professional services firm for dentists. Thomas & Fees Seminar Schedule LAW March 6, 1998 May 8, 1998 May 29, 1998 INFECTION CONTROL March 27, 1998 May 29, 1998 OSHA March 6, 1998 March 27, 1998 May 8, 1998 |
An OSHA Inspection That Could Have Been Avoided! On occasion, I do emergency OSHA consulting. Usually, I get a frantic call, "Come quick -- an OSHA inspector is at my door!" I received such a call recently. I'd like to share what prompted this inspection and how they could have easily avoided it. The dentist in question owns a successful practice in southern California. On a Thursday morning he was treating a patient, with his assistant working chairside. Just at the end of the procedure he got a phone call from his wife. Their son had fallen out of a tree and was unconscious. The ambulance was there and the young boy and his mom were leaving for the hospital. Naturally, the dentist dropped what he was doing and within minutes was out the practice door. Luckily, the treatment on the patient had been completed and there was nothing left to do except escort the patient to the reception room and clean up the operatory. During the dental procedure that had just concluded, the dentist bent the needle so he could inject lidocaine into a recessed molar area. Ordinarily, the dentist would have disposed of the bent contaminated needle himself. But because he had left in such a hurry, the job was left up to his RDA. As would happen, she poked herself. The assistant was frantic. The needle stick had been deep and there was some question as to the patient's health. These two factors, the fact that the exposure incident had been serious and the questionable health history of the patient, contributed adversely to the situation. Unfortunately, this dentist was not one of our OSHA clients. He had no "Exposure Control Plan" or protocols for handling needlesticks. So, what do you think the assistant did when she and the other frightened staff members couldn't figure out what to do about the needle stick? Who do you think she called to ask for assistance? You're right. She called OSHA. OSHA doesn't have the people power to inspect all the businesses that have complaints against them. They are more apt to send a written or faxed complaint in lieu of an in-person visit. But not when the complaint is for "eminent danger." Not when an employee calls and says, "I've been stuck with a contaminated needle and I'm worried that the source patient may have AIDS." The result of this phone call was an OSHA inspector standing at the door bright and early the next day. When the dentist discovered what prompted the inspection, he was furious with his assistant. But after further discussion he calmed down and realized he had no one to blame for his predicament but himself. His employee had not been trained on how to handle an exposure incident. She honestly believed her life was in jeopardy and since no one was available to give her advice, she went to OSHA for help. We don't ordinarily recommend you refuse OSHA entrance into the practice. It angers the inspector and usually guarantees a more hostile inspection. But, in this situation, we were forced to do just that. The office was not in compliance. So the office manager was instructed to tell the inspector that he lacked the authority to allow him onto the premises. The inspector left, promising to return with a court order. To quote him exactly, "I'll be back. And, I'll be inspecting this practice for weeks." This dentist was lucky. Over the weekend, we were able to train the employees, clean up the office and get it into compliance, except for the correct handling of the exposure incident. The inspector returned at our request on Monday and without the warrant. The inspection was made and fines were levied at just over $1,100. From this incident we can see why employee training is the backbone of OSHA compliance.
Employers are responsible for the safety of their employees and employees can't be safe
unless they are properly trained. Training must be given at initial time of assignment and
repeated annually as outlined in the Bloodborne Pathogens Standard. Besides, if you don't
train employees and a problem arises . . . they may call OSHA for help. |
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