By Pamela Dembski Hart, Healthcare Accreditation Resources LLC
I attended the annual OSHA Health and Safety (Bloodborne Pathogen and HAZCOM) training recently provided at our dental practice. I inquired when I would receive the OSHA certification form. The instructor informed me that……
Contrary to what you may have heard from the rumor mill, OSHA does not actually certify workers and you cannot get “OSHA certified”. Courses and trainers are considered OSHA “authorized” or in “accordance with the training requirements”, and attendees must receive required course completion documentation (and not just a certificate of attendance).
Anyone claiming to be OSHA certified or offering OSHA certification other than from the Department of Labor (DOL) would be seriously incorrect and making false claims.
OSHA certification is only achieved when an individual attends a 10 or 30 hour OSHA Outreach training, which is provided by OSHA authorized trainers and results in the issuance of an official Department of Labor (DOL) OSHA 10-Hour or 30-Hour card.
Staff do not need an official DOL card to achieve OSHA compliance. However, your dental staff does need annual site specific training regarding OSHA’s Bloodborne Pathogen Standard, the Hazard Communication Standard and General Duty clause. Also, the new HAZCOM training requirements which were mandated since 2012 regarding OSHA Globally Harmonized System/HAZCOM.
Training must be interactive site specific, offer the attendee the opportunity to ask questions and to obtain an immediate response to the question. Web based training must make provisions for an immediate response to any questions. (e-mail is NOT an immediate response.) Quizzes alone do not meet the requirement of OSHA training.
Also regarding CE’s: according to PACE/AGD, the MA BORID and nationally recognized guidelines 55 minutes of live training = 1 CE. Basically that means that a 2 hour course would equal 2 CE’s and NOT 3!
Finally, reference MA BORID regulations, which as of July 1, 2016 the Board and the DHPL office of Public Relations will begin random audits of all licensed dentists regarding compliance with 234CMR 8.00, the boards regulation regarding continuing education.
Listed below are the facts according to current law regarding training and include the appropriate regulatory text number.
Information and Training.
Employers shall ensure that all employees with occupational exposure participate in a training program which must be provided at no cost to the employee and during working hours.
Training shall be provided as follows:
At the time of initial assignment to tasks where occupational exposure may take place;
At least annually thereafter.
Annual training for all employees shall be provided within one year of their previous training.
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. The additional training may be limited to new exposure or adverse events
Material appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used.
The training program shall contain at a minimum the following elements:
An accessible copy of the regulatory text of this standard and an explanation of the regulations
A general explanation of the epidemiology and symptoms of bloodborne diseases;
An explanation of the modes of transmission of bloodborne pathogens;
An explanation of the employer’s exposure control plan and the means by which the employee can obtain a copy of the written plan;
An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;
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;
Information on the types, proper use, location, removal, handling,decontamination and disposal of personal protective equipment;
An explanation of the basis for selection of PPE… and the list goes on to include several other required training elements.
HAZCOM (29 CRF 1910.1200) Training: Includes new(2012) GHS requirements
Employee Information and Training.
(h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.(SDS’s)
Employees shall be informed of: The requirements of this section;
- Any operations in their work area where hazardous chemicals are present; and,
- The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by this
(h)(3) Training. Employee training shall include at least:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
- The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and,
- The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.
- December 1, 2013 – By this date, employers must train employees on how to read GHS formatted labels and SDSs. Changes to labels are probably more substantial, however, employees need to understand where to find information on the SDS, especially in section 2 where critical hazard information is
- June 1, 2016 – By this date employers should be fully compliant with HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating safety data sheet manuals and secondary
Information listed above does not include information about the required HIPAA training, Infection Prevention and Control training (per CDC guidelines) and the Massachusetts Board of Registration in Dentistry. Retain all (OSHA) training records for a period of 5 years/per BORID (OSHA mandates retention for 3 years)
Pamela Dembski Hart, BS, MT (ASCP), CHSP, is Principal and Founder of Healthcare Accreditation Resources LLC.
She can be reached at:
Pam is an approved PACE Program Provider, FAGD/MAGD Credit. Approval does not imply acceptance by a state or provincial board of dentistry or AGD endorsement Provider ID#368382 (3/1/16 to 2/28/18)