Are you in danger? OSHA is Seeking to Regulate Workplace Violence Prevention Programs

By Olivia Wann

OSHA published the Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers and now plans to release a proposed rule in December which would be effective in 2025.

Interestingly, California dental practices were required to establish, implement and maintain a workplace violence prevention plan July 1^st of this year, regardless of how many employees are in place.[1]

Earlier this year, we were quite shocked to read that a dentist in Louisiana was stabbed multiple times and may lose her eye. The criminal entered the dental office to talk to the dentist. Evidently, she chased the dentist around the office with a knife.[2]

How would you respond in such a dangerous situation?

OSHA recommends you identify and assess workplace violence hazards. A risk factor in dentistry is working with people who have a history of violence, abuse drugs or alcohol, gang members and relatives of patients.

Another risk factor is poorly lit parking lots, especially in high crime areas. If you practice in a metro city in a large office building, perhaps you can relate to the potential fear of leaving for the day and facing the possibility of being a victim of a crime while you walk to your vehicle.

Implement a violence prevention program. This includes:

• Management commitment and employee participation,
• Worksite analysis,
• Hazard prevention and control,
• Safety and health training, and
• Recordkeeping and program evaluation.

As in any business endeavor, management commitment is key in order to have an effective workplace violence prevention program. This involves allocating resources—including the time to create a program, maintain the tools, possibly make some modifications to our office layout, and keep people trained.

Management should work closely with team members in identifying and assessing hazards.  Just like we would incorporate an engineering control to isolate or remove a bloodborne pathogens hazard from the workplace, we can incorporate an engineering control to remove a workplace violence hazard.  For example, engineering controls could include:

• A barrier at the front desk with locked patient entrance doorways with a keyless door system
• A well-lit parking lot
• Panic buttons
• An alarm system
• Maintaining a clear exit route

In providing training, include ways to deal with hostile people. This could be a patient’s relative such as a spouse or significant other. I remember a case from 2012 where the dental receptionist was murdered. She was shot shortly after arriving at work. The killer was her husband who later shot himself.[3]  

We’ve all experienced the wrath of a toxic patient. How do we know whether a rude, arrogant patient or family member is going to morph into a dangerous situation?  It may be helpful to learn verbal de-escalation strategies. Assess if you have a safe room where team members can take shelter from a potentially violent situation.

Incorporate an active shooter plan.[4] A future article will delve into greater details on this serious topic.

Be aware that OSHA will soon adopt the workplace violence prevention program on a federal level soon and update your policies in order to keep your dental teams safe and in compliance.