Demystifying OSHA Training Requirements for the Dental Clinic

Q:           Do dentists and dental clinic staff have to have OSHA training?

A:            Yes. Initially (at first employment) and annually. Bloodborne Pathogen Standard 1910.1030(g)(2)(i) says “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.”
Additionally, “employers shall provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure.”

Q:           What is Occupational Exposure?

A:            Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.

Q:           Can someone from my staff perform the training?

A:            Bloodborne Pathogens Standard 1910.1030(g)(2)(viii) says “The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program.” That same section of the law also requires that the training cover 14 specific areas (see list), and that trainings be recorded in a training log and kept for at least three years. If you have such a person on your staff with the time it takes to administer all of this consider yourself lucky. If you are not so lucky, leave OSHA training to the professionals.

Q:           Can I (dentist) perform the OSHA training?

A:            Yes, but the real questions is should you perform the training. Simply put, dentists should think twice before doing any task that does not involve direct, or management of direct patient care. Dentists only make money when they are seeing patients, and clinics only stay open when employees are getting paid.

Q:           Can’t they just read a manual?

A:            Bloodborne Pathogen Standard 1910.1030(g)(2)(vii)(N) says a trainee must have “an opportunity for interactive questions and answers with the person conducting the training session.”

Q:           Does the revised Bloodborne Pathogens standard apply to medical or dental offices that have fewer than 10 employees?

A:            OSHA's Bloodborne Pathogens standard applies to all employers with employees who have occupational exposure to blood or other potentially infectious materials, regardless of how many workers are employed. However, the offices and clinics of medical doctors and dentists are exempt from the requirement to keep a log of occupational injuries and illnesses and thus exempt from maintaining a sharps injury log. (See Appendix A to Subpart B of 29 CFR Part 1904.) All other applicable provisions of the Bloodborne Pathogens standard still apply.

Items that must be covered in an OSHA Bloodborne Pathogen training program

(vii) The training program shall contain at a minimum the following elements:
(A) An accessible copy of the regulatory text of this standard and an explanation of its contents;
(B) A general explanation of the epidemiology and symptoms of bloodborne diseases;
(C) explanation of the modes of transmission of bloodborne pathogens;
(D) An explanation of the employer's exposure control plan and the means by which the employee can obtain a copy of the written plan;
(E) An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;
(F) An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment;
(G) Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment;
(H) An explanation of the basis for selection of personal protective equipment;
(I) Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;
(J) Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;
(K) An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available;
(L) Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident;
(M) An explanation of the signs and labels and/or color coding required; and
(N) An opportunity for interactive questions and answers with the person conducting the training session.