It seems lately that dental laboratory inspection have once again been on the Minnesota OSHA radar.
These are just some of the common Inspector requests I have had during the almost 14 inspections I have gone through.
What happens during a OSHA inspection?
When they come into your lab ask them why they are in your lab. You have the right to know, you may also deny them entry. Please keep in mind that they can and most likely will get a warrant from a court to enter your facility if you refuse entry.
If they are there to inspect on something you no longer do at the lab such as Hexavalent Chromium, ( gas from casting chrome cobalt metal) you can explain that you do not do that procedure and politely ask them to leave. Keep in mind they have the authority to levy fines. I have had them then say that they are there for a random inspection. It is a fine line you should walk if you ask them to leave.
What triggers an inspection? Death or serious injury in the workplace, complaint from someone, usually a current or former staff member, specific reason such as airborne silica, or a random inspection. Lately in Minnesota OSHA has been doing random inspections.
There is a time line on reporting a death or serious injury, please know the rules.
In my opinion it does not make sense to refuse entry and have them get a warrant, they may not be in the best mood when they return.
Some things that OSHA Inspectors have looked at in the past:
· Infection Control Protocol, make sure you have written procedures and posted by your infection control area.
· Proper Personal Protection Equipment (PPE) for all staff and visitors. Make sure staff is using PPE when and where appropriate. It must also be in good condition.
· When using hazardous chemicals such as acid, chemical googles with no vents on the top should be used. Do not hang googles by the elastic strap as that strap can stretch and then the goggles will not fit. Trust me this could result in a fine.
· Complete First Aid kit is required. Check and make sure it is adequately stocked.
· Safety Data Sheets (SDS) are current and available to all staff during normal working hours. Make sure staff knows where the SDS info is located.Save old SDS for materials that you no longer use.
· Eye Wash station is in working order and is the Paddle type station installed to proper procedures.
· Bench lamps have three prong grounded cords.
· No extension cords.
· Properly grounded outlets (GFI) near water.
· Blood Born Pathogen (BBP) training for all staff is up to date. This must be completed each year. Have written record that staff has signed acknowledging BBP training with instructors name, date and length of course.
· Hepatis B shots information on all staff. The lab must offer free of charge to staff. If they refuse now have them sign the OSHA declination form. Only use this form if they have never had Hep B shots. If they change their mind at a future date the lab must pay for the shots. If they had shots at a time previous to your employment you need to have the dates of those shots.
· OSHA 300A report forms, usually they ask to see the three previous years. Make sure the current form is posted if between the dates of February 1 and April 30th.
· In case of an injury fill out the report of injury forms.
· They will speak with staff one on one, sometimes every staff member. Make sure staff knows what to do in emergency situations, such as fire. Where should everyone meet, who is in charge of counting bodies once you are outside. Have evacuation plan posted in the lab in various places, along with tornado shelter. Exits must be clearly marked and doors that may be confused as an exit clearly marked as Not An Exit.
· Signage for Main Gas shutoff controls if you have gas in your lab.
· Tornado shelter posted.
· Employee posters are properly posted in an area accessible to all staff. Lunch room is a good location.
· Do you have chemicals properly labeled? Global Harmonization System (GHS) utilized in the lab?
· All material properly labeled? Most common issue when some liquid is shipped in a larger container, such as a gallon, and transferred to a small spray bottle. Is that new container properly labeled?
· If you have lathes in the lab and only use one end of the lathe, does the other end have a cover over the spinning shaft?
· Proper covers on casting machines? Applies to broken arm units also.
· Dust evacuation for grinding, including silica.
· If you require use of masks, have you had the staff member Fit Tested?
· Proper Sharps containers and numerous spread out through the lab?
· No food at the bench, all liquid containers must have a lid.
· All safety guards on machinery are in place
· Lock out Tag Out procedure in place.
· Designated Safety Coordinator known to staff. This person should know where to find all records on items such as training records, Hep B info, etc.
· Make sure that your Safety Manual is up to date with all information.
· Clean your lab.
· Although OSHA may not check, please make sure you have your I9’s in order.
· Post information on emergency care facility in case of injury.
There are two separate divisions of OSHA in Minnesota and Wisconsin. One is the Enforcement Division and they do the inspections due to death, complaint, specific issue and random. They will levy fines for violations.
If you have a random inspection and violations are assessed along with fines. You will have a time limit to correct the violations. There is a fee reduction schedule based on number of employees. Most of the time they will apply that formula to the fine. You have the right to contest the violations and fines.
There is also a Safety Division, which you may call and set up a inspection. They will come in and do the same type of inspection, if you have violations you will still be required to correct the violations but you will not be issued any fines unless you fail to correct the violation. The three different Safety Division inspectors I have worked with in Minnesota and Wisconsin are exceptional and very helpful.
This division will also do training for you, and air/noise quality testing.
Neither of these divisions share information with each other.
When you set up an inspection with the Safety Division you will be issued a letter stating that you are under the Safety Divisions control for an inspection and if an inspector from Enforcement Division comes to your lab you will show that to the inspector and they will leave under most circumstances.
This is not in any way a complete list of what you need to do to meet OSHA requirements. These are just some observations that I have encountered during my OSHA inspections. Each Inspector seems to have their favorite areas that they concentrate on during an inspection. Make sure you educate yourself on lab safety.
New staff members are required to receive Blood Born Pathogen training within ten days of employment. Also Minnesota requires Right To Know training within those ten days. Every state requires training on a yearly basis. Make sure training is done the same time every year, by a qualified person.