OSHA is at the Door, Now What!?
by Sally McKenzie CEO
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“Doctor, there’s an OSHA inspector here to see you.” Now that’s a line that you just never want to hear. But if your business employee quietly calls you away from your patient and delivers that urgent message, will you be prepared?
Certainly, random inspections of dental practices are not commonplace, but they do happen and typically they are precipitated by a complaint to the Occupational Safety and Health Administration from either a patient or an employee. Who would do such a thing? You may never know. Those who complain to OSHA are not required to identify themselves and can remain anonymous. The anonymous complaints usually prompt a letter and require the dentist to reply within five days with supporting documentation proving the allegation isn’t true. Whether the complaint is valid or not is irrelevant. It’s a complaint and OSHA will check it out and expect you to respond.
If the individual, filing the grievance gives their name, OSHA will conduct an onsite inspection. And if an inspector is in your dental practice, they will take the time and effort necessary to carefully examine the safety systems of the entire practice in excruciating detail making it far more likely that a violation will be discovered.
So how do you prepare for this not-so-welcome visit? Don’t open the door. In other words, take steps to ensure that OSHA doesn’t have cause to visit your office, starting with a strong internal communication system. The goal is to ensure that in your practice employees feel completely at ease bringing matters to your attention that they feel could be potentially harmful.
Always listen to employee concerns and either take action on the issue or thoroughly explain to the staff member why they do not need to worry. But don’t dismiss them or imply that they are foolish in raising the issue with you. You want them to ask questions and make you aware of circumstances that may be completely safe but could be perceived as problematic. Keep in mind that if one employee is raising the issue, it’s likely been discussed among the staff at large and perhaps even in front of patients.
Oftentimes, it is how well a doctor handles the internal communication with employees and/or patients that dictates whether they find themselves having to defend their practices against an OSHA complaint.
In addition to open communication systems, make sure you have clearly established compliance protocols in place in your office as well. For example, every practice should have a written Hazard Communication Program on file and available to all employees that includes the following:
- A list of all hazardous chemicals present in the practice.
- A description of the labeling system used in the office to warn against chemical hazards.
- An explanation of the procedures for obtaining Material Safety Data Sheets (MSDS).
- Documentation of employee training.
In addition, practices must comply with the Bloodborne Pathogens standard. It requires:
- A written exposure plan, which is updated annually.
- Identification of those employees covered by the standard.
- A list of job classifications.
- Methods of compliance.
- How specific wastes are regulated.
- Documentation that Hepatitis-B vaccinations have been received by all employees.
- Post exposure records on any employee who has had an incident, requirements for reporting exposure incidents, requirements for maintaining medical records on employees with occupational exposure.
- Annual staff training covering several issues regarding bloodborne pathogens.
Get the team involved in compliance. Appoint an OSHA compliance point person. This employee is your safety officer or compliance officer and should be very detail-oriented and able to manage the practice’s OSHA program. She/he knows where all OSHA documentation and records are located. She/he makes sure the practice has OSHA illness/injury logs available and they are up-to-date. This person ensures that the required safety programs are in place and documentation proving that required safety training has taken place and emergency protocols are in place and on file. She/he manages the OSHA manual and ensures that it is current. And she/he verifies that clinical employees have received the required Hepatitis B series and maintains the necessary records.
The doctor should periodically review the steps the employee has taken and confirm that necessary records, logs, and other documentation are in place. see
Next week, Do’s and Don’t’s when the inspector comes to call.
Interested in speaking to Sally about your practice concerns? Email her at email@example.com.
Interested in having Sally speak to your dental society or study club? Click Here.
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Leadership is a Contact Sport
Have you been told you’re “too serious”?
Do you hate “small talk”?
Find that you prefer working alone in your office rather than with your staff?
Ever been accused of being aloof or ‘hard to read’?
Is leading your team a draining experience?
If you answered ‘yes’ to these questions, chances are you’re an introvert. No, you don’t need psychoanalysis or medication. There’s absolutely nothing wrong with you. However, if you want your practice to be more productive and profitable you will need to “stretch” outside your interpersonal comfort zone.
Leadership is a process by which a person influences others to accomplish specific goals and objectives. As such, the basic nature of leadership is interaction between people. This is a dynamic, relational process aimed toward making the team more cohesive and powerful.
If you’re an introvert – or if you have introverts on your staff – this can be difficult. Introverts are not necessarily shy (although shy people are introverted). Shyness is about feeling anxious or frightened in social situations. Most introverts are not necessarily apprehensive. In fact, introverts can have great ‘people-skills’; they just find other people tiring.
Science has learned a good deal in recent years about the habits and requirements of introverts. Through brain scans, we know that introverts process information by thinking and reflection. Introverts need time to mull things over. They need solitude to recharge and rejuvenate. For introverts, people are okay…in small doses.
In my coaching and leadership training with dentists, I have found that introverted dental leaders can be wonderfully warm and witty…with their patients. But when it comes to employees, they’re just worn out. Low on interpersonal fuel, many introverted leaders rely on hibernation – they retreat to their office and close the door. Employees are left on their own with little to no guidance, direction or support. It’s no wonder that teams can run amuck.
There’s no doubt that introverted dental leaders need time to tune out and recharge. I am not suggesting that you change your private nature and become a flaming extrovert, but you do need to shift your behaviors to engage more with your team. These are skills you can develop and practice.
Introverts can be outstanding leaders. They listen better. They think through issues in more depth than their extroverted counterparts. They are more focused. When they speak they are more concise.
On the other hand, introverts must remember to:
- Engage with and affirm your employees. Give positive feedback. Ask staff about their families or the purchase of a new car. Conversely, tell them about something fun you did on the weekend.
- Express thoughts rather than rehearsing ad nauseum. This is especially true when something displeases you. For introverts, problems in the office are internalized. Introverts can spend so much time in inner dialogue that issues don’t get discussed openly. This can snowball into serious conflict.
- Seek out opportunities to convey your message to your team. Plan to let your staff know more about your practice vision at staff meetings. Remind them during morning huddles. Great ideas can be expressed in short segments of time. Script it. Come up with a few talking points on important practice issues.
- Add a little enthusiasm to your words. This is a skill you can practice with the help of a tape recorder or with a trusted ally. By putting more ‘punch’ to your communication you will ignite more believability and credibility in your message.
- Be the first to speak rather than the last. By going first, you’ll be more relaxed as you listen to others. In turn you may actually speak up more.
- Reduce the amount of time you spend in your office. Walk around. Have lunch with employees at least once a week.
- Say ‘good morning’ when you come in each day. Never leave without saying goodbye or letting your staff know you’re stepping out of the office for a while.
- Smile. Misunderstandings are often based on small nuances…like an overly somber facial expression or a frown. When you smile, it shows others that you are approachable and confident. Employees will want to follow.
If you are an introvert, celebrate your strengths. Remember that your natural gifts are essential for team harmony. Your style can be calming and reassuring during stressful situations. Now it’s time to expand your skills. The key is to remind yourself and – as Nike says – just do it.
To learn more about your communication preferences and the impact on your practice, contact Dr. Haller at firstname.lastname@example.org.
Interested in having Dr. Haller speak to your dental society or study club? Click Here
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Where Have All My Patients Gone?
Dr. James Wilcox– Case Study #111
“My practice has stagnated over the past couple of years. The town where I live is growing and more and more dentists are moving in. It doesn’t seem like I am as busy as I used to be. What is happening?”
Dr. Wilcox’s practice facts:
- 15-year old established family practice that sees about 15 new patients a month. Five years ago the practice was averaging 20 new patients a month.
- The practice has supported 4 days of hygiene for the past 5 years.
- The practice has maintained the same staff for almost 7 years.
“I used to be so busy that I considered stopping the influx of new patients. I couldn’t keep up the pace and my patients were waiting weeks to get in. Now I am only scheduled out a week or two in advance and there are days that I am not busy at all.”
- The “receptionist” was too quick to tell patients that they didn’t accept any PPOs.
- The office was “out of date” in terms of décor.
- The staff, including the hygienist, referred to the hygiene appointments as “just cleanings”.
- There were no “recall protocols” for the receptionist to follow in order to maintain a healthy recall program.
- Dr. Wilcox told his patients during their 6-month exam that “everything looks good”.
- No one in the office asks for referrals from their existing patients, nor is there a sign that invites new patients to the practice.
- The “New Patient Experience” was non-existent
These observations are very common in practices that have been around for 10-15 years. It’s like all of you have been “around the block” and keep going around the same block instead of moving to a new one. It is evident you keep doing everything the way you used to do them!
For example, here a few questions asked of Dr. Wilcox:
- Why don’t you call your patients after difficult procedures?
- Why don’t you hand-write a thank you note to a new patient?
- Why don’t you participate in more local community projects to get public visibility?
His response to all the above questions was the same. “I used to. I just don’t get around to it anymore.” Dr. Wilcox wins the “round tuit” award for the month. How can you afford NOT to get around to it? Coasting on your past success in hopes that the same success will continue without applying any effort is irresponsible. It doesn’t work in this economy with new dentists coming to your area and who have learned and been “raised” on how to market to their patients.
- Start implementing more internal marketing techniques, such as hand written thank you notes, celebrating patients’ birthdays with a small gift when they arrive, participate in community activities as a team for exposure, etc. Many of these ideas “used to be done” before the good life set in.
- Increase patient awareness relative to the hygiene program. If they want patients to stay in the practice, patients need to understand the value of what the hygienist does. She performs “professional cleanings” and educates patients on how to maintain their dental investment. Dr. Wilcox must express to each patient the importance of coming in for their scheduled intervals for maintenance and prevention of dental diseases.
- Establish a “New Patient Experience” like nothing that a patient would experience in another office. Conduct blood pressure screenings, oral cancer screenings, have a new patient gift package, see new patients within a week for excellent customer service, don’t have new patients wait, schedule the new patient appointment for what the patient wants, which is a “cleaning”. Combine the hygiene visit and the new patient doctor visit at the same time.
- Invest in a “new look” for the office. Get rid of the orange shag carpet and uncomfortable chairs lined up around the wall. Bring in an interior decorator if necessary and bring the reception area into the 21st century. Display professional dental posters with people of all ages with beautiful smiles. After all, isn’t that what we do?
- Follow the new “recall protocol” for improving patient retention. It doesn’t do any good to get 15 new patients in the front door if 20 existing patients are leaving through the back door because of poor customer service and lack of follow-up. Every patient must feel that YOU are their dentist and they would not even consider trying the “new dentist” down the street!
Dr. Wilcox’s practice was a very common example of the challenges that all doctors face when they don’t keep up with the times and continue to utilize all the tools that they first used to build up the practice. If you have a good thing going, keep it going and don’t get off the path. Never assume that your practice will continue to grow and flourish unless you are willing to nurture and care for it every day.
Dr. Wilcox now understands this concept and is re-establishing many of the internal marketing strategies that he and his staff used to exercise. The office has become energized again and it is again a fun place to work.
Throw away your “round tuits” and start nurturing your practice again. It will start rewarding you with the fruits of your labor.
If you would like more information on how McKenzie's Practice Enrichment Programs can help you IMPLEMENT proven strategies….. email email@example.com.
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