Five things you should do during inspections,

1. Ask questions
2. Take notes and photos
3. Don’t argue with the inspector
4. Walk around with the inspector
5. Ask the inspector for their suggestions

Q: What governmental agencies are most likely to inspect our office?

A: Although there are about seven agencies that are responsible for regulating dental offices, the top three and most active are,

1. OSHA
2. Consumer Affairs (Dental Board)
3. Department of Health Services

Q: Why would the Dental Board want to inspect my office and if I am not there is my staff required to let the inspector conduct their inspection?

A: In most cases when an inspector from the Dental Board visits an office they are following-up on a compliant filled by a patient or staff member. There are other reasons why a dental office is inspected by the Dental Board like licensing issues, random compliance inspection, field audits, etc. The Dental Board inspectors have the authority given to them by regulations to inspect your office anytime during business hours.  The regulations do not specify that owners, managers, partners, etc. must be present during the inspection. By the way, based on the make-up of regulations the Dental Board has more regulations requirements for dental offices than OSHA!

Passing a Delta Dental inspection is a good thing but not a gauge for an inspection by OSHA or the Dental Board.  I get calls everyday from Dental Offices that passed Delta Dental inspections with flying colors but didn’t pass OSHA or Dental Board inspections.  They call me for advice and direction wanting to know what went wrong and how-to correct the problem. The answer is quite simple – set the right standard and do the things to achieve it.  Example – if you set a standard to pass a Delta Dental inspection you will not pass inspections that require a higher standard.  This is why 9 out of 10 Dental Offices fail inspections, their standards are too low.

My advise – establish a standard that every patient will receive the highest quality of care and the highest level of safety, then do the things to achieve it  in other words make your office “Patient Compliant”, your office will pass every inspection every time. Remember it isn’t government regulations that makes a dental office safe it’s the people who work in it!

Q: I heard that OSHA doesn’t have the manpower to inspect dental offices, is this true?

A: NO! – This is one of the biggest OSHA myth among the Dental Profession, OSHA has plenty of manpower for inspections and keep this in mind, only one OSHA inspector needs to come through the doors of your office and if your office is not compliant which by the way 9 out of 10 dental offices are not, manpower shortage isn’t the issue anymore. Another thing, with fines in the thousands of dollars range I would make sure my office is compliant and not just with OSHA requirements either. The day that dentists must stop taking the “cheap” route is here – protect your patients and employees and you will protect your assets, it’s a no-brainer!

Q: My OSHA Consultant says if an OSHA Inspector comes to my office that the Inspector cannot inspect the office without making an appointment with my consultant and that my consultant must be present during the inspection. What is your opinion?

A: My opinion – your OSHA Consultant is an idiot. OSHA Inspectors are not required to make appointments with consultants prior to an inspection or wait for the consultant to be present before conducting the inspection. As a courtesy most OSHA Inspectors will contact the consultant after the inspection to discuss finding, reports, citations, request documentation or provide suggestions for improvement but are not required to do so by law.

Q: We have a member of the staff who is designated as our “OSHA Coordinator”, however I am not sure if she is keeping up-to-date with all of the regulations. What can I do to keep her current?

A: About 99% of the dental offices that fail inspections has someone on the staff who is appointed as the OSHA Coordinator or Compliance Coordinator, this person is trying their very best to keep the office compliant but will fail every time, Why? Because they are not an expert, how can your OSHA Coordinator who must learn and apply the regulations requirements of on an average six regulatory agencies, which makes changes several times a year, be on top of things when she is spending 95% of her time attending to patient care responsibilities? The majority of OSHA Coordinator fails because they do not have the knowledge, experience, skill, and time that are needed to become an expert. Dental Offices will continue to fail inspections and be unsafe environments for both patients and staff until the owners change their mindset and put the safety of patients and staff above all else. What can you do to keep current? Change your thinking!

Q: My office received a phone call from a company wanting to schedule a date and time for a mandatory OSHA inspection. Is OSHA using this company to inspect Dental Offices?

A: No – it is a private company trying to sell you products and services, they are NOT affiliated with OSHA in anyway. I recommend never let anyone inspect your office without first confirming who they are and what agency they are with. Do not be intimidate with inspectors or those pretending to be inspectors!

Q: We were told that if an inspector came to our office, we can refuse to let the inspector conduct the inspection and request he or she make an appointment with our OSHA consultant, is this sound advice?

A: NO – not even close to being sound advice it’s more like BS. I suggest you do three things,

1. Get your office compliant
2. Be ready for inspections
3. Fire your idiot OSHA consultant

Written plans are mandatory by law, must be current and enforced, failing to do so will result in fines and increased liability. During an inspection, inspectors (government & insurance companies) will review your Compliance Manual, what they are looking for is sound policies & procedures that are complete and current. In addition, they are looking for records showing staff members have read the manual, received ongoing training, and management enforces the policies & procedures.

1.  Compliance Manual components have been updated as of 6/1/09.

2.  Compliance Manual components are “site-specific” written for your office and staff.

3.  Compliance Manual contains policies & procedures based upon City regulations.

4.  Compliance Manual contains policies & procedures based upon County regulations.

5.  Compliance Manual contains policies & procedures based upon State regulations.

6.  Compliance Manual covers the following topics (or similar),

• Prevention Program
• Hazard Assessment
• Hazard Communication
• Hazard Correction
• Infection Management
• Exposure Management
• Waste Management
• Emergency Protocols
• Safety Protocols
• Accident Investigation
• Exposure Investigation
• Recordkeeping Policy
• Staff Training Policy