As an employer, you're bound by the Occupational Safety and Health Administration (OSHA) to carry out its vision that "every employer and employee in the nation recognizes that safety and health add value to American businesses, workplaces and workers' lives." Of course, you share OSHA's concern for your employees' safety, but sorting through the applicable OSHA regulations can be a daunting task. So where do dental laboratories most often go wrong?
During OSHA's last fiscal year--October 2003 through September 2004--dental laboratories received 17 federal citations:
Eight of the citations were for Hazard Communication
Three for Respiratory Protection
Three for Personal Protective Equipment
One for Means of Ingress, meaning that all exits must be marked and unobstructed
One for Compressed Gases
One for Machines
There are also 26 states* with state-run OSHA programs and, during that same time period, labs in four of those states received citations (information on California was not available):
Maryland: two citations for smoking-prohibition;
Nevada: seven citations for means of egress (exit), electrical systems design, and bloodborne pathogens;
North Carolina: six citations for hazard communication, personal protective equipment, oxygen-fuel gas welding and cutting, and electrical wiring methods;
Washington: six citations for safety committee, accident prevention program, hazard communication.
To help you determine your responsibilities and ensure you're ready should OSHA come knocking, here's a closer look at the three violations for which dental laboratories are most often cited:
1. Hazard Communication (29 CFR 1910.1200)
Lack of compliance with the Hazard Communication Standard (HCS) is consistently the top violation for laboratories and usually ranks at the top for other industries as well. The purpose of the HCS is to ensure that workers and their employers are informed of the identities of hazardous chemicals, associated health and safety hazards, and appropriate protective measures. OSHA requires chemical manufacturers and importers to evaluate the hazards of each chemical and prepare labels and material safety data sheets (MSDSs) to convey the hazard information. Laboratory owners must have these labels and MSDSs for all hazardous chemicals used in their workplace and must train their employees how to handle the chemicals appropriately.
Here are some guidelines on how to comply with the HCS:
Review the MSDS (many laboratories request a product's MSDS prior to making a purchasing decision)
Determine health and safety risks to the employee
Develop good work practices to eliminate or minimize exposure
Install engineering controls when needed
Provide personal protective equipment when needed
Identify and maintain a written list of hazardous chemicals (this list is separate from the MSDS)
Provide an immediate warning to the employee of the hazards of working with the product by placing an appropriate label on the product
Train employees how to handle the chemicals safely.
2. Respiratory Protection (29 CFR 1910.134)
This standard states: "In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section."
Examples of air pollutants in the dental laboratory that require technicians to use respiratory protection--when engineering controls don't eliminate or minimize the exposure--include monomer fumes; dust generated from working with or finishing beryllium- or nickel-containing alloys; and silica dust generated when mixing investment, divesting, mixing and grinding porcelain, sandblasting, cleaning work areas, and cleaning or changing filters in dust collection equipment.
You must provide the respirator that is applicable and suitable for the purpose intended as well as establish and maintain a written respiratory protection program that includes selection criteria; medical evaluations of employees required to use respirators; fit testing procedures; procedures and schedules for cleaning, disinfecting, storing, etc.; and training for employees required to wear respirators. The respiratory protection program must be administered by a suitably trained program administrator, which can be an employee who has been trained by a health and safety professional.
The best way to ensure that technicians are not being exposed to harmful dust or fumes is to test the air in the areas where the hazardous chemicals are being used. Private companies conduct this testing or you can contact OSHA's consultation division in your state and request an assessment. The testing is usually completed by placing a pump in the work area for a specified amount of time or having technicians wear a measuring device during their usual shifts.
If you determine that a respirator is not required, then voluntary use of respirators is allowed and the employer simply provides the employee with a copy of Appendix D of the Respiratory Protection Standard. A written respiratory protection program would not be required.
3. Personal Protective Equipment (29 CFR 1910.132)
This standard instructs that "Personal Protective Equipment (PPE) devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls and sound manufacturing practices." Part of this standard also provides compliance assistance to help you meet requirements for a hazard assessment and the selection of the proper PPE.
Your responsibilities are to conduct an assessment by surveying the laboratory to identify sources of hazards to workers, for example, flying objects, hot items, dust or fumes. Then, you must prepare an analysis of the findings, select the PPE which ensures a level of protection greater than the minimum required to protect the worker and fit the worker with the protective device. For example, since flying objects are possible in the laboratory, everyone in production areas must wear safety eyewear. This includes all administrative staff members and even visitors who enter production areas. The safety eyewear you provide must be rated by ANSI (the American National Standards Institute).
Laboratory owners are also responsible for reassessing the workplace as necessary and training employees on cleaning and maintenance of the PPE. Be sure to maintain this information in writing and be prepared to substantiate to OSHA why and how you selected the PPE being used in your lab.
OSHA initiative, published reports should cause laboratory owners to take heed
OSHA's five-year Strategic Management Plan, covering 2003 through 2008, sets goals and strategies to build on OSHA's base of success and enhance its work for the future. The Agency's resources are being directed toward the following goals:
Reduce occupational hazards through direct intervention;
Promote a safety and health culture through compliance assistance, cooperative programs and strong leadership; and
Maximize OSHA's effectiveness and efficiency by strengthening its capabilities and infrastructure.
By 2008, OSHA's goal is to reduce workplace fatality rates by at least 15% and workplace injuries and illnesses by at least 20%. It is especially concerned about high incident/high severity industries, amputations in manufacturing and construction, ergonomics, blood-lead levels and silica-related disease.
The emphasis on silica-related disease should certainly alert dental laboratory owners because of the many products used in laboratories that contain silica. In fact, the Centers for Disease Control published a report in a March 2004 issue of Morbitity and Mortality Weekly Report regarding silicosis in dental technicians. Prior to that, in April 2002, OSHA also focused on health risks to dental technicians in its Trade News Release about exposure to beryllium. With this public recognition, it is likely that more dental laboratories will be visited by OSHA this year and in the years to come.