Karen Daw, MBA, CECM
The newest dental office in town promotes itself as a heavenly oasis. In the waiting area, written in embellished cursive, is a sign that promises a relaxing dental visit and invites patients to ask about add-on services such as Botox and teeth whitening. Lavender aromatherapy greets patients when they arrive, and the sounds of Enya can be heard throughout the spacious office. A customized saltwater aquarium lines the side wall. The plump waiting room chairs sit on ornately carved wooden legs.
The front desk team wears matching sweaters with their names embroidered on them that are color-coordinated with the beige and black accents of the office. The lower level of the office is a dedicated training facility and conference room, complete with a drink station and large-screen television. The clinic has a total of 12 rooms, six operatories on each side, that line a long, winding hallway. The beige walls are accented by white Corinthian columns, and grapes droop from the latticework overhead, imitating a Grecian garden.
I had just completed the Occupational Safety and Health Administration (OSHA) infection control training and was conducting a mock inspection of this office accompanied by a safety officer, a hygienist. At the start she confided that she had concerns about some of this office’s infection control practices. I thought, “Surely I’m not going to find much in such an immaculate palace.”
However, by the end of the assessment, the practice had amassed an inordinate number of “opportunities” for correction. Some of the things we observed were running the ultrasonic without the lid on (with a glass of orange juice sitting nearby), not changing out barriers or disinfecting surfaces between every patient, and team members exiting restrooms without washing their hands and then setting up cookies for arriving patients.
What steps should be taken?
So, what should hygienists do when their office has substandard infection control and safety practices?
It may seem like a no-brainer, but starting the conversation is one of the hardest things to do, and communication is the first step. Liz Ramsey, a dental hygienist with the practice of Beth Loew, DDS, said, “I’ve never worked in an office with substandard infection control, but I’ve heard of other hygienists who have. They sought advice from their peers, who advised that they bring their concerns to management and then report if there is no change. I feel comfortable speaking up about a lack of safety. I would suggest approaching a colleague in a nondemeaning way and discussing the situation as it affects not only my safety, but theirs as well.”
If a colleague is practicing substandard infection control, a heart-to-heart talk might help the person understand the repercussions of the lax behavior. Many employees sign a “Condition of Employment” contract with the practice regarding safety and professionalism. Being able to reference this document when you broach the subject reminds them what they committed to. It can also prevent bad blood between you and the offender by avoiding a me-against-you scenario.
One of my favorite techniques for difficult discussions is from Susan Scott, author of Fierce Conversations.1 She lays out steps that occur in 60 seconds to initiate a challenging conversation. In a nutshell, begin with the concern, explain why it’s a concern, give specific examples, and end with an invitation for the person to respond. This way there is no misconstruing the intent, and the other person feels heard.
But what if, despite your best intentions, the person won’t listen? Then it’s time to take things to the next level and share your concerns with the doctor and practice manager. Employers are aware of their responsibilities under OSHA and the state dental board and are sensitive to complaints. If they’re unaware of the problem, they will not be able to make changes. For this reason, most employers promote an open-door policy and reinforce the message so that team members feel comfortable sharing their concerns. Employers can then take the necessary steps to address the unsafe practice.
Sometimes a practice fails employees by not setting expectations and not providing training. OSHA requires training in bloodborne pathogens upon hiring and yearly. While designed to protect employees, following OSHA standards benefits patients too. Many states also have requirements for infection control continuing education. The Centers for Disease Control and Prevention (CDC) even has the DentalCheck app, which is also available in paper format at cdc.gov/oralhealth/infectioncontrol/dentalcheck.html. It’s a good self-assessment tool for dental hygienists and an observational tool for safety officers to ensure CDC infection control guidelines are being followed.
On a personal level, you should set an example for the team by attending infection control training and share those opportunities with others in the practice. There are many ways to learn about infection control, and some are even free.
Ms. Ramsey said, “I personally get as much continuing education as I can, and I also reach out to fellow hygienists via social media groups and outlets.” Dr. Loew has her team attend multiple infection control and OSHA courses each year. “My employer makes sure we are always up-to-date on training and we often discuss OSHA and infection control during our monthly staff meetings.”
What if the employer is negligent?
But what if the employer is dismissive of your concerns or is the one promoting an unsafe environment?
If the concern has to do with your safety or that of a coworker, and you’ve brought this to the employer’s attention and been rebuffed, you can contact OSHA. To file a complaint online, by phone, or by mail or fax, visit osha.gov/workers/file_complaint.html.
Infection control expert Noel Kelsch, RDHAP, interviewed OSHA in RDH magazine, who said, “We want to see more working men and women return to their loved ones at the end of the workday. Prevention is the key. That’s why OSHA is your resource for safety and health information.”2
OSHA writes, “The Occupational Safety and Health Act of 1970 gives employees and their representatives the right to file a complaint and request an OSHA inspection of their workplace if they believe there is a serious hazard or their employer is not following OSHA standards. Workers do not have to know whether a specific OSHA standard has been violated in order to file a complaint. The complaint should be filed as soon as possible after noticing the hazard or lack of compliance because OSHA citations may only be issued for violations that currently exist or existed in the past six months. Complaints from workers or their representatives are taken seriously by OSHA. OSHA will keep your information confidential. Your employer can not retaliate against you for filing a complaint.”3
In some instances, you may not have a choice but to contact OSHA. In the unlikely event of a work-related fatality or the hospitalization of three or more employees in a single incident, the nearest OSHA office must be contacted. Call (800) 321-OSHA or your state plan for assistance.
If the grievance involves patient safety, you have the right to contact your dental board. Like OSHA, some states also allow employees to file a complaint anonymously.
Finally, trust your gut. It just might be time for you to look for another practice where everyone attends ongoing continuing education, where there is open communication regarding infection control, where following nationally accepted standards for safe practices is motivated by more than possible fines and license suspensions, and where going above and beyond in infection control is about doing the right thing. In the ideal workplace, your safety and that of your patients should be a primary focus. To me, that practice sounds heavenly!
1. Scott S. Fierce Conversations. Penguin Random House. New York, NY. 2002.
2. Kelsch N. Ready to report, Part 1: Contacting OSHA. RDH magazine website. https://www.rdhmag.com/articles/print/volume-29/issue-2/columns/infection-control/ready-to-report-part-i-contacting-osha.html. Published February 1, 2009.
3. Workers’ Rights. OSHA website. https://www.osha.gov/Publications/osha3021.pdf.
Karen Daw, MBA, CECM, “The OSHA Lady,” is a writer, authorized OSHA trainer, speaker, and safety consultant. With previous experience as Clinic Health and Safety Director for the Ohio State University College of Dentistry, her focus is on assisting dental practices in safety compliance. Visit theoshalady.com.