My take on the 2017 Industry Survey from SafetyCulture

This year I had the honor and privilege to be a part of the safety industry survey conducted by SafetyCulture for 2017. The report is located here: SafetyCulture 2017 Industry Survey.

The survey brings to light some great achievements in the last year regarding the culture and implementation of successful safety programs. However, there are also some areas of concern. Specifically in regards to gender equality in the safety field and issues that are increasing the risks and hazards within our organizations.

Let’s look at some of the positive areas first. Reporting and audit tools have moved in large portions to digital mediums and cloud-based reporting. This allows for quicker hazard identification and mitigation planning, as well as increased accountability and task assignment. Processes and work sites also make up a majority of the areas inspected for positive safety habits. This is an incredibly effective way of ensuring that the root cause (the processes themselves) are being held under the spotlight to identify hazardous or dangerous environments.

Another positive area of improvement is the proactive safety cultures within many organizations. The average number of near misses (averaged from the thousands of us that participated in the survey) was only 103.54. While that may sound like a lot, and in some industries it may be, the biggest takeaway from this factor is that near-misses are being reported! This is something we have struggled with from an enforcement and compliance view for many years, near-misses were just not being reported at all.

Serious incidents were averaged out at 4.43 over the last 12 months! This is an incredibly low number, especially since we are also averaging the construction industry into this survey. The construction industry, which makes up the largest majority of our safety community, has been in the lead for fatalities and serious incidents for a very long time. Hopefully, we are seeing a trend where this industry is adopting a more positive view of the safety culture.

The last positive item I want to discuss is the viewpoint that regular (not intermittent or last second) safety training and evaluation is considered one of the greatest factors in reducing safety hazards. As a compliance consultant and trainer, I am overjoyed to see that our hard work and diligence to providing training is beginning to be viewed positively. Yes, I know that your annual OSHA training is still pretty boring, or you have to be evaluated again on how to safely use an angle grinder, or back the company vehicle up WITH a spotter, or wearing gloves during a patient exam. However, in the long run adopting a positive attitude towards this will lead to less injuries and potential fatalities (or backing up the ambulance into a column… Ahemmm from what I heard…. I have always used a spotter……).

However, there were some areas of concern identified in the survey as well. Many of these items have been prevalent for many years in the world of safety management. Hopefully, over the next few generations of safety professionals will see a dramatic shift from the plateau we seem to be at with these issues.

The first area that we need to see a shift in is with the education and training of safety professionals. As the survey indicates, the construction industry makes up the largest portion of our safety professionals. Within this industry sector, formal training programs are not commonly required or utilized. This is in stark contrast with other sectors where formal education and training programs, or degrees in safety are required. A formalized training program or degree requirement is not an elitist opinion, it is really about ensuring continuity across the broad spectrum of safety in regards to regulation interpretation and application. Imagine if we had lawyers that in certain states did not have to go through law school before taking the Bar Exam. We would end up with legal counsel that may have just guessed well enough to pass the exam and are now representing clients. This would lead to inconsistencies and may not allow for adequate legal advice, even though they are lawyers that passed the exam. It was mentioned in the survey that the construction industry is trending towards more formalized requirements for their safety professionals, this will help to bring a continuity factor throughout every industry and hopefully, bring the construction out of the top spot for fatalities and work related injuries. I do realize that it will still be a large number due to the industry being larger than many of the others combined, however, many of the violations cited by OSHA in the construction industry are due to a lack of full comprehension in regards to regulations. Inconsistencies in enforcement, especially in utilizing PPE such as a PFAS while working at heights or adequate construction of scaffolding, seem to be a root cause of this sector having a high fatality and injury rate. Formalizing the requirements for training would help to train safety professionals early on in their career to be stricter on enforcement of regulations. Of course, that is just my opinion from years of working in multiple industry sectors, and I hope to see more effective enforcement in the future.

This also leads into the next item of concern, the aspects that increase the risk of workplace hazards. Leading the pack is time pressures, couple this with the next few areas of employees being under trained, and poor hazard planning, and we have a recipe for disaster. Of course there will always be time pressures in our careers, however, when the safety culture is reactive and unable to adequately plan for hazards or appropriately train employees, those deadlines become a walk on the razors edge of potential mishaps or fatalities.

The last two items of concern are the prevalence of under reporting or lack of reporting near misses or injuries and that many safety professionals feel their organizations could be doing more with the data they do have. Safety is, unfortunately, many times a “lessons learned” career, meaning we cannot easily predict outcomes for hazards until an injury occurs. Think of guarding on blades or turning parts, safety regulations on guarding became mandatory, but only after many decades of injuries being considered an acceptable risk. There is an interesting history of this presented in a brief power point I found a while ago while researching the subject. Have a look at it: Machine Guarding.

The issue of not reporting a near miss or injury is always a concern. We need the near miss and injury data to adequately plan and prevent hazards before an injury occurs. I know this has been on an upward trend of more reporting, however, it is still a major concern for many safety professionals. There is plenty of incentive to not report injuries or near misses, but a lesson I learned early on was that by not reporting we are only hurting our chances of providing a safe environment for the employees that have put their trust in us.

There was much more data and statistics in the report than I have brought up here, however, I feel these were the most important areas to focus on. In my daily life as an OSHA compliance consultant I see many areas that could use better implementation of their safety programs. Much of this has to do with the safety culture that is fostered from the top of the organizational hierarchy. If the top does not see safety as important, chances are the compliance with safety regulations will be lacking and the safety professionals are complacent. The future of being able to provide safe working environments depends on safety professionals firmly guiding organizations into a proactive approach towards compliance and enforcement.

OSHA and the Dental office

All too often I run into a common thought process in many dental practices is that an OSHA inspection is not a very likely issue to worry about. This leads to a reactive compliance program that is not fully prepared for the day an inspector walks in unannounced. Not only will this create a panicked process for the dental team, a lack of proactive compliance will potentially lead to hefty fines. How common are violations and fines in dental practices? Lets explore this a bit.

Before we discuss the types of violations we commonly find and the amount of the fines, we need to clear up some misconceptions. OSHA inspections are not announced and can occur at any time. They can be initiated by a complaint or as a scheduled random inspection. Regardless of why OSHA decides to visit your practice, if the compliance program does not fully cover all regulatory requirements, violations and fines will be issued. Violations are categorized into three different “pay-scales”, ranging from minor violations to serious repeat offenses.

The first grouping is where the most common violations are found. “Serious”, “Other-Than-Serious”, and “Posting Requirements” incur fines to the practice of $12,675 per violation. According to OSHA the most commonly cited violations in dental offices in 2016 were:

  • Bloodborne pathogens requirements.
  • Hazard communication (Remember those new SDS libraries we have you set up?).
  • Inadequate use of Personal Protective Equipment.
  • Medical services and first aid (Yes, you have to have a first-aid kit in your practice! Oh, and the ADA standard of care to have an AED on site? Yes, that can be a violation as well if you don’t have one).
  • Cluttered or inadequate walking/working surfaces.
  • No Ionizing radiation protocols or safeguards.
  • Forms (This means not having the five required OSHA paperwork items for each employee. These are:
    • Proof of Annual OSHA Training
    • Occupational Exposures Form/Occupational Hazards per each Job Title
    • Proof of GHS Training
    • Proof of Hepatitis B Vaccination Form
    • Medical History (on-file) for Each Employee (updated annually)
  • Maintenance, safeguards, and operational features for exit routes (Yes, even a $2 light bulb to replace the burned out one in your exit sign can cost you $12,675…. oh and $2 for the bulb).
  • Sanitation (I don’t need to say much on this, keep your practice clean).

If we think about all of these, which are not an all inclusive list of violations cited, how many could be found in our practice right now? Now add up the $12,675 per violation. Would your practice survive?

This is the worst case scenario for an OSHA violation though. Many times violations are given abatement periods with much smaller fines. Most inspectors understand human nature and will work with the practice to fix the issues. However, this does not develop a proactive approach to regulatory compliance and if that lesson is not learned, the same pattern will be repeated.

The next category of of fines is “Failure to Abate”. Remember how I mentioned that inspectors will give an abatement period? Unfortunately, some practices do not take the citations seriously. This will lead to a fine of $12,675 PER DAY, PER VIOLATION past the abatement date!!!!! Let that sink in for a moment, even one unabated violation can close a practice. This may lead to the question “OSHA doesn’t give us enough time to fix the issue!” Well, let me dispel that right now. Plenty of time is given to abate the violation, true it may take some of the staff away from patient care for a while, but that is the price of fostering a reactive “knee-jerk” culture.

The final, and most egregious, is the “willful” and “repeated” violations. These carry a maximum penalty of $126,749 per violation. However, this is reserved for those practices that refuse to correct previously identified violations and show a willful disregard for staff and patient safety. An excellent example of this is a case study conducted on a dentist a few years ago. OSHA inspected the practice due to a patient complaint that the instruments used still had blood and tissue from a previous patient on them. It was discovered that the dentist and his staff were not wearing any PPE, were not sterilizing instruments correctly, and were not performing biological spore testing on the sterilizers. The abatement period was broken and none of the violations were corrected, then upon a second complaint the same violations were categorized as willful and repeated. After OSHA finished shutting him down, he was turned over to the state dental board.

This is an extreme case, but it does highlight the true disregard some have for the safety of others. The majority of us want to ensure our practices are safe and in compliance with all regulations. The reason most fall short is the sheer amount of requirements that must be in place and constantly worked on. This leads the majority of practices to live in a constant state of reactivity towards regulatory compliance.

Many of my clients become discouraged and half-jokingly say “I just want to be a dentist, not an OSHA expert….” This is a sentiment I can not disagree with! Eight to twelve years of medical school and specialization to all boil down to citations for not knowing every aspect of federal regulations is ludicrous! Fear not though, there is a bright light at the end of the tunnel. That light is created through fostering a culture of proactive compliance and comprehensive programs. Don’t have the time to research and create one from the ground up? Well, you are in luck!

There is an industry leading compliance consulting company that has paved the way in this area. Their consultants range from Registered Dental Hyginests and Expanded Function Dental Assistants to Dental Instructors from the U.S. Air Force and Occuptional Safety Managers with experience in building compliance programs for large medical training groups and hospitals. The company, Dental Enhancements Inc. has clients nationwide with a return customer base of nearly 98%!

Dental Enhancements Inc. has been an industry leader nationwide in comprehensive compliance programs that fulfil all federal mandates for over 15 years with excellent results. However, I am not trying to sell you on the company, I invite you to look into their compliance programs and other comparable ones. Or even look into resources to build your own! The whole goal is to build a culture of proactive and comprehensive regulatory compliance. That way when the OSHA inspector walks in and shows you his badge, you can smile and say “we’ve got this!”.