Employee Standards

The OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) is designed to protect workers exposed to blood or other potentially infectious materials (e.g., saliva in dental procedures), and covers training, hepatitis B virus vaccination, personal protective equipment, engineering and work practice controls, housekeeping, and regulated waste. OSHA has a "quick reference guide" for the Bloodborne Pathogens Standard. 

A component of OSHA compliance is a written exposure control plan, which applies to both bloodborne pathogens and hazardous chemicals (in 29 CFR 1910.1020). The OSHA publication, Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards (2003), contains sample exposure control plans for both.

The Occupational Safety and Health Act of 1970, Section 5, Duties, states:

"(a) Each employer - (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct."

In the absence of specific standards, this General Duty Clause covers occupational safety in dental offices, including ergonomics, nitrous oxide, and workplace violence, and other occupational safety and health exposures.

As part of the Personal Protective Equipment (PPE) regulation, OSHA has established a subsection describing the PPE hazard assessment process for determining potential workplace hazards and implementing control measures. According to Subsection 1910.132(d), Hazard assessment and equipment selection, the employer must asses the hazards that may demand the use of certain categories of PPE, and further (1) make available the appropriate PPE for each hazard type, (2) communicate these PPE requirements to staff, and (3) ensure proper fit. Finally, the employer must verify the hazard assessment in a written document, including information regarding the workplace assessed, the person verifying the assessment, and the date the hazard assessment occurred. Nonmandatory compliance guidelines on conducting the assessment and implementing requirements can be found in Appendix B to Subpart 1. For dentistry, examples of workplace hazards include no only the risk of airborne and bloodborne pathogens, but also chemical, eye and noise hazards.

Requirements pertaining to respiratory protection PPE such as N95 masks are found in Subsection 1910.134, Respiratory Protection. In a workplace where respirators are necessary to protect the health of the employee, or whenever respirators are required by the employer, the employer must develop and implement a written respiratory protection program with required worksite-specific procedures and elements. More information about OSHA's respiratory protection standards are available in the OSHA publications Respiratory Protection and Small Entity Compliance Guide for the Respiratory Protection Standard.

General information about identifying and assessing hazards in the workplace is available in an OSHA resource entitled Recommended Practices for Safety and Health Programs: Hazard Identification and Assessment for the general workplace, which describes six steps in detail:

1. Collect existing information about workplace hazards
2. Inspect the workplace for safety hazards
3. Identify health hazards
4. Conduct incident investigations
5. Identify hazards associated with emergency and nonroutine situations
6. Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control

According to "Frequently Asked Questions" regarding the OSHA Bloodborne Pathogens Standard, employers are responsible for laundering gowns and lab jackets. Dental practices may install washing machines in the office, they may contract with commercial laundry services, and disposable gowns and jackets may also be used. Scrubs, if worn under PPE, are generally not covered by the laundry requirements of the standard unless the scrubs do become contaminated with blood or other potentially infectious materials. Employees are not permitted to take contaminated laundry home.

Personal protective equipment (PPE, including gloves, gowns, masks, and eye protection) must be provided by the employer as well as cleaned and maintained to provide functional and protective efficacy, according to 29 CFR 1910.132. It is the responsibility of the employer to assess risk from hazards and to make appropriate PPE available. Employees may use their own PPE, but the employer is responsible for its maintenance and cleaning. Further information from OSHA is available on their PPE Safety and Health Topics page. Frequently asked questions regarding PPE use in dentistry are posted on OSHA's website in a Standards Interpretation Letter. The Bloodborne pathogens standard also addresses PPE, at section 1910.1030(d)(3) of the CFR.

The OSHA Ionizing Radiation Standard (29 CFR 1910.1096) regulates occupational exposure and covers exposure and control. This Standard is incorporated in the following recommendations.

The ADA/U.S. Department of Health and Human Services' Dental Radiographic Examinations: Recommendations for Patient Selection and Limiting Radiation Exposure contains a section on "Operator Protection" that addresses occupational safety, including the wearing of dosimeter by pregnant personnel, barrier shielding, and work practice controls such as standing behind the direction of the beam. Recommendations for hand held x-rays units, including holding the device at mid-torso height, orienting the shielding ring properly with respect to the operator, and keeping the cone as close to the patient's face as practical. 

Additional information on radiation safety for dentistry may be found in Radiation Protection in Dentistry, a publication of the National Council on Radiation Protection and Measurements.

Employers are responsible for offering the Hepatitis B Virus Vaccination to employees within the first ten days of an employee beginning their position. Employers are also required to cover the cost of the vaccinations. Employees may refuse vaccination, and OSHA provides a declination form for this purpose. An employee who has refused the vaccination may opt to receive it at a future date. No booster is currently recommended for persons with normal immune status who have been fully vaccinated. Although studies are ongoing to assess whether booster doses of HBV vaccine will be needed in the future, recently published data from a 30-year cohort follow-up suggests that booster doses may not be needed.

Other vaccinations for health-care personnel that are not regulated by OSHA, but may be required under state law, include the seasonal influenza vaccine; other strongly recommended vaccinations can be found on cdc.gov.