Risky Business: OSHA is Alive and Well
Risky Business: OSHA is Alive and Well
From the looks of the OSHA activity so far this year, our industry may see 2010 as a banner year for OSHA inspections. If you’re in the state of Minnesota, in particular, make sure you’re ready for that visit. We are aware of five inspections of dental laboratories in that state within the past few months. Another one of our clients, Triad Dental Studio in Greensboro, N.C., also received a NC-OSHA inspection this year. Martha Martin, CEO of Triad, stated that, “The inspection was unannounced. The inspector stated that this was a computer generated inspection and OSHA was targeting the medical industry.”
Martha said that the inspector was very thorough during his six hour inspection even though he admitted that this was his first inspection of a dental laboratory in his 17 years of inspections. What a great laboratory for him to learn on, however, this gives laboratories a lot to live up to! Following the opening meeting with the officers and safety coordinator, the inspector conducted a walk thru of the laboratory including having general discussions with officers and the safety coordinator, reviewing the safety manual, meeting with selected technicians at his choosing (one-on-one from each department), and lastly, conducting a closing meeting with officers and the safety coordinator.
The following list details the areas of the lab inspected and the specific items addressed by the inspector:
Shade Taking Room:
- Procedure for taking custom shades.
- Disinfection of shade tabs.
- CDT personal protective equipment – glasses, mask, gloves, lab coat
- Disposal of X-Rite shade tips
- Area cleanliness
Server Room:
- Cleanliness
- Proper cord placement
Hot Room:
- Standard Operating Procedures for Case Check in and disinfection
- Requested MSDS for disinfectant used
- Length of time disinfectant is left on impressions.
- Eye Wash station availability
- Reviewed Hot Room MSDS binder.
- PPE for Hot Room
- Proper Storage for PPE
- Proper use of Biobags
- Use of case pans
- Posted Hazard Communication Signage
- Use of hazard labeling on secondary containers
Case Entry / Customer Service:
- Observed computer stations
- Observed computer and electrical cords were up off floor.
- Checked outlets for power supply via voltage tester.
- Checked copiers for grounding via ground tester.
Model and Die:
- Observed general use of equipment by technicians, model trimming with dry grinder, sitting at workbench using hand piece.
- Observed lathe with spindle not in use but had protective cover
- Checked plaster hoist for operation - verified monthly maintenance inspection and sign off. How was it filled and who was responsible?
- Monitored employee use of PPE.
- Observed sitting positions at worktables.
- Inspected work tables – sides, tops, underneath, inspected connections for gas, etc.
- Observed use of Zuebler suction system – how does it work, where does the dust go.
- Observed rubber mat placement for standing.
- Inspected Fire Extinguisher for storage, monthly on-site inspection, yearly
Cleaning Supply Room:
- General cleanliness and organization.
- MSDS books for cleaning products.
- Safety training for contracted cleaning group regarding lab products and safety.
Inventory Storage:
- Observed how inventory was stored.
- Observed MSDS labeling.
- General cleanliness
- Verified proper storage of gas tanks – chains secure, labeling correct
- Observed Lockout Tag Out – yearly training – who does training – who is responsible for lockout tag out.
- Discussed what type of equipment retains energy at lab.
Compressor Room:
- Observed signage.
- Inspected all electrical panels
- Observed taped off area around panels to avoid items being stored in front of panels that would impede access in an emergency.
- Observed Zuebler suction systems – discussed how operated and maintenance.
- Checked electrical outlets.
- Observed compressors and absorbent control barrier on floor around compressors.
- Checked for dust accumulation – not more than 1/32 of an inch – very important due to combustibility potential of dust.
Burnout Room:
- Observed extraction canopies on timers.
- Observed acid station and use of PPE.
- Types of acids used.
- Verified and reviewed MSDS for acids in Burnout Room MSDS binder.
- Observed sand blaster and dry trimmer – safety shields in place.
- Observed burnout ovens and cooling area.
- Observed induction casting.
- Observed refrigerator for supplies and signage (For Production Use Only)
- Observed suction system for divesting
- Observed acid spill kit and fire blanket.
- Observed cleanliness of area.
Crown and Bridge:
- Observed investment area, signage for PPE, and suction system.
- Observed mixing technique for investment.
- Discussed Silica.
- Reviewed MSDS for Silica products in Crown and Bridge MSDS binder.
- Observed metal finishing.
- Observed full contour waxing
- Observed laser welder – optics - protect eyes from laser beams
- Gas tank at laser.
- Checked work tables and equipment for proper grounding.
Porcelain:
- Observed technicians at work tables utilizing magnification while grinding porcelain.
- Verified bottles for labeling – “distilled water – production use only”
- Observed Sharps’ Container and asked how we disposed of contents
Signature Studio:
- Observed technician in training.
- Discussed the use of duplicating machine.
Employee Break Room and Kitchen:
- Checked stand alone water cooler and vending machines for proper grounding.
- Inspected kitchen area.
- Checked outlets via voltage meter.
First Aid Station, Emergency Shower:
- Checked cleanliness.
- Checked for monthly inspections.
- Discussed how emergency shower is inspected.
Employee Bathrooms:
- Cleanliness
- Hot and Cold Water, soap dispensers, paper towels.
Outside Building:
- Verified gas line shut off labeling.
- Walked around outside of building.
General Questions and Discussions:
- Emergency Evacuation Plan – posted and training for emergency situations.
- Safety Training – Annually, semi-annual. Documentation of training.
- Monthly safety meeting – safety committee - who attends, topics, notes of meeting, how is information conveyed to other employees.
- Safety Consultant – on-site yearly training, walk through, updates.
- Chemical Inventory List – inspected.
- Observed signage throughout the lab – warning, safety, PPE, etc.
- Observed footwear – no open-toe shoes.
- Discussed Mandatory Labor posters – where they were placed and up to date.
- Discussed Injury Report for Dental Labs.
- Discussed PPE selection for each job category and documentation for each employee.
- Observed personal safety handbooks for each employee.
- Randomly verified Hep B information and where it was located in employee health files.
- Verified and Discussed Respirator Program. Yearly fit test. Who does test? Documentation and which test is utilized.
- Discussed needing to set base line in our lab for Silica via Industrial Hygienist.
- Reviewed Safety Handbook – went through contents page and then checked for Hazard Communication Plan, Exposure Control Plan, Standard Operating Procedures for Infection Control, Respirator Program, Hazard Communication Standard, Blood borne Pathogen Standard.
Results of the Inspection:
The inspector was extremely impressed with the safety program at Triad and the excellent condition and cleanliness of the facility. Even though Triad had implemented a respiratory protection program for certain areas where there is silica exposure, NC-OSHA has required Triad to have base line testing performed by an industrial hygienist. Also, an additional eyewash station must be added to the hot room so it is within 10 seconds walking distance from possible injury site.
An exciting result of this inspection is that the inspector indicated that he plans to recommend Triad Dental Studio as an applicant for the voluntary protection program also known as the STAR program. The Carolina STAR Program is designed to recognize and promote effective safety and health management. In STAR management, labor, and OSH establish a cooperative relationship at a workplace that has implemented a strong program. Congratulations to Martha and Matt Martin at Triad Dental Studio for being invited to participate in this program and we encourage all dental laboratories to be willing to show OSHA your commitment to a safe workplace.
