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How to prepare for dental OSHA inspections

September 30, 2020

The past year experienced a 200 percent increase in OSHA inspections nationwide, compared to the average of the previous 20 years. Why the sudden jump? What, if anything, are OSHA inspectors looking for in dental offices more than in other health-care settings?

The catalyst could well be one recently issued document: the CDC’s Summary on Infection Prevention for the Dental Setting. This 44-page précis is a revised update to just about every infection-control ritual performed by dental professionals over the last 50 years. OSHA endorses (and enforces) these revisions as the “new industry standard” to which all dentists must adhere. Just one serious violation will bring the unprepared practice owner a $13,000 fine. Multiply that by the 20 updated protocols within the CDC summary, and you can see there’s cause for alarm.

What explains these changes? The CDC has studied dental-practice infection control and disease transmission for decades. In 2016, with OSHA’s support, the CDC finally compiled this new summary, to which all dental offices in the United States will be held accountable. The bottom line: Regardless of your specialty, you’ll have to practice according to this new standard. The guidelines require practice owners to set up and execute “hospital-grade-level sterilization and disinfection protocols,” and provide written documentation that your office is following them.

Don’t be fooled into thinking that the CDC’s supposed “guidelines” are optional. In 2008, OSHA endorsed having the CDC establish standards for disease transmission and infection control given that the CDC, as a research organization, is best placed to set those benchmarks. They establish the minimum standards; you ignore them at your considerable peril.

How best to prepare?

Start by downloading the CDC summary, available at cdc.gov/oral health. Study it—no, devour it. Implement the new protocols and make sure all your employees understand the requirements in detail. At the back of the summary there’s written documentation; be sure to fill it out. In essence, the CDC is giving you a free infection-control update. (That’s the glass-half-full way to look at it, anyway.) Beware, though: The document isn’t the lightest reading. I’ve determined that a dental team will need about 10 hours to read and digest the protocols, and another 10 hours for meetings and implementation.

Shortcuts? Sure. Benco Dental, for example, has a great new program called Focus on Infection Control, which offers four tutorials on implementation. It’s a great way to launch your updated program—ask your Friendly Benco Rep for details.

Bear in mind, finally, that this 44-page update makes up just 10 percent of your overall OSHA written requirements. (That’s the glass-half-empty viewpoint.) As you read the

new material, if you find yourself confused or overwhelmed, feel free to reach out to me—my contact info is below—for clarification. I can offer more complete solutions as well. This can all be intimidating, but proper infection control makes for an airtight dental environment to the benefit of patients, staff and practitioners alike.
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JILL OBROCHTA, RDH, BS is the Florida-based founder of Dental Enhancements, an OSHA and HIPAA solutions company. She offers no-obligation consultations and can be reached at 941-587-2864 or jill@dentalenhancements.com.

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