OSHA Cites a Dental Office Over Laundry Procedures

by Olivia Wann and Caitlin Denison

Recently, a dental practice received a serious OSHA citation for contaminated laundry being handled unnecessarily or with what the inspector described as “excessive agitation.” This was surprising, as in 26 years of consulting we have not previously encountered this type of violation.

For many years, our guidance has emphasized placing a biohazard label on hampers used for contaminated cloth jackets and lab rags, as well as requiring appropriate personal protective equipment (PPE) when handling such laundry. However, we had not previously seen the specific language “excessive agitation” used in this context.

According to the OSHA inspector, the violation occurred when an employee checked the pockets of lab jackets before laundering them. The inspector considered this action to be excessive agitation under the standard. Without explicit language in the Work Exposure Control Plan addressing this issue, the employee may not have been aware that such handling could be considered a violation.

To better align office procedures with the Bloodborne Pathogens Standard and OSHA’s current interpretations, we have issued a supplement to the Exposure Control Plan addressing the procedure for handling contaminated laundry to all of our subscribing clients. Policies will also be revised during the annual update for subscribers whose service packages include policy updates. Keep in mind that even with a detailed laundry procedure in place, an OSHA inspector may still cite a violation if they observe an employee not following the plan. It is not enough to simply have the appropriate policies written; the practice must also demonstrate that those policies are being consistently followed.