Regulatory Compliance
C D A J O U R N A L , V O L 5 0 , Nº 4
Cal/OSHA Citations of Dental Practices CDA Practice Support
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review of Cal/OSHA dental facility inspection data from October 2016 to September 2021 provides useful information to dentists who seek to reduce compliance risk. A total of 37 dental practices were inspected during this period, 43 fewer dental practices than the previous five years.1 The assumed reason for the significant drop in the number of inspections is the COVID-19 pandemic. Twenty-two of the 37 inspected facilities were cited for a total of 44 violations. All but one of the cited facilities had between 1 and 3 citations. One dental practice was cited for five violations.2 The most common citation issued to dental facilities was for failing to have a written injury and illness prevention plan. Ten facilities did not have the required written plan. Facilities also were cited for: ■ Not having a system of communicating workplace hazards to employees. ■ Not having a procedure to investigate occupational injuries and illnesses. ■ Not maintaining records of scheduled and periodic inspections One dental practice’s citation for not having a procedure to investigate occupational injuries and illnesses was part of the agency’s COVID-19 inspections. The citation, categorized as “serious,” has an initial penalty of $3,150 and is being contested at the time of this writing. In addition to the items listed above, a written injury and illness prevention plan must: ■ Identify the person(s) with authority and responsibility for implementing the program.
Describe a system for ensuring employees comply with safe work practices, such as recognition program, disciplinary actions and training. ■ Include methods or procedures for correcting unsafe conditions or work practices. If a dental practice claims exemption to the Cal/OSHA Aerosol Transmissible Disease (ATD) regulation, the plan must include procedures for screening ■
patients for ATDs and management of patients suspected of having an ATD. A COVID-19 prevention plan must be either a standalone plan or an addendum to the injury and illness prevention plan. Sample plans are available on cda.org/practicesupport as part of the Regulatory Compliance Manual. Several citations were issued for violations of the bloodborne pathogens regulation during this period. The violations included:
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