Workplace Standards

OSHA requires disinfection of environmental surfaces with an "appropriate disinfectant". Appropriate disinfectants include a diluted bleach solution and Environmental Protection Agency (EPA)- registered antimicrobial products. Fresh solutions of diluted household bleach made up every 24 hours are also considered appropriate for disinfection of environmental surfaces and for decontamination of sites. Contact time for bleach is generally considered to be the time it takes the product to air dry.

OSHA does not require offices to replace carpet in dental operatories, nor does it address the type of flooring in the Bloodborne Pathogens Standard. In terms of the cleaning routine (29 CFR 1910.1030(d)(4)(i)), OSHA states the "employer must determine and implement an appropriate written schedule of cleaning and decontamination based upon the location within the facility." The Centers for Disease Control and Prevention (CDC) suggest "replacement with nonporous material when it is time to replace flooring."

Eye and face protection is covered under 29 CFR 1910.133, and OSHA provides an e-tool to assist in selecting appropriate protection according to hazard. It is the responsibility of the employer to assess risk from hazards such as "liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation" and to ensure that proper eye protection is utilized.

Safety data sheets that accompany products used in dental offices identify which products are corrosive and/or caustic. The OSHA standard for Medical and First Aid (29 CFR 1910.151), contains a requirement that employers provide "suitable facilities for quick drenching or flushing of the eyes and body" in situations where employees may be exposed to corrosive materials. 

In a Standard Interpretations Letter, OSHA has acknowledged that the Standard does not require employers to have an emergency eyewash if none of the materials used in the work area is an injurious corrosive chemical; however, the letter also states:

"...while not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI Z358,1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of 'hazardous material' would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans."

In the event of an inspection of a dental office where corrosive materials are in use, a workplace without an eyewash station (i.e., "suitable facilities"), could be cited by OSHA under 29 CFR 1910.151(c). Information about eyewash stations is available from the Organization for Safety, Asepsis, and Prevention (OSAP).

For dental offices with state occupational safety plans, consult your area administrator for applicable requirements.

While 29 CFR 1910.151 addresses the first aid kit and first aid training required at all workplaces, it does not include specific guidance about a first aid or emergency kit for a dental or medical office, nor does it provide a list of required contents. Many states have adopted the ANSI Z308.1 specifications for minimal contents, and it is highly recommended that contents are suited to meet the expected needs of the dental practice. OSHA provides an appendix to 1910.151, First Aid Kits (Non-Mandatory), which states, "employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately."

Needle safety may be approached through both work practice controls- such as prohibition of two-handed needle recapping, and engineering controls such as sharps containers, masks, gloves, and devices for one-handed needle capping. "if recapping must be performed, it must be accomplished by means of a recapping device which adequately protects the hands or a properly performed one hand scoop technique." Engineered needle safety products are also ways to help reduce and eliminate percutaneous exposure. Needleless systems, if available, are recommended. Resources on "Safer Needle Devices" may be found on the Bloodborne Pathogens Standard page on evaluation and controls.

Requirements for sharps containers can be found in section 1910.1030(d)(2) of the Bloodborne Pathogens Standard. Containers for contaminated sharps must be closable, puncture resistant, leakproof on the sides and bottom, appropriately marked or color-coded, ad kept upright during use. Mounting the container unit is a method of keeping it upright, but it is not mandatory.

Please note that OSHA does not specify where sharps containers are to be located in a dental office. OSHA has indicated that the employer is to determine placement based on location accessibility and reasonable proximity to the area where sharps are used. According to the answer to Question 39 in OSHA's Frequently Asked Questions Concerning Bloodborne Pathogens Standard, "Sharps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used (e.g., patient care areas) or can be reasonably anticipated to be found (e.g., laundries).

OSHA does not regulate sterilization of dental equipment, but state and local regulating authorities or dental boards may require compliance with CDC infection control standards.