OSHA Standards & Requirements

The Occupational Health and Safety Administration (OSHA) establishes standards, guidelines and promotes health and safety in the workplace in the United States and its territories. It applies to private-sector employees and employees.

OSHA covers full-time, part-time, temporary, contract, and per diem employees. Employers must be familiar with all applicable standards. The full text for these can be found at www.osha.gov. Employers and employees must comply with the guidelines and standards.

OSHA Standards, Requirements, and the Dental Office

OSHA standards and requirements that are normally applicable to dental settings include but are not limited to:

• General requirements (includes PPE, walking-working surfaces)
• Bloodborne Pathogens Standard
• Hazard Communication Standard (revised)
• Ionizing Radiation
• Formaldehyde
• Exit Routes
• Electrical

Additional OSHA standards may apply to some offices. In states and territories with OSHA-approved state plans, there may be regulations in addition to those required by Federal OSHA and listed above. The complete text of regulations is available in Title 29 of the Code of Federal Regulations (29 CFR).

OSHA-Required Training

OSHA mandates training for all employees falling under OSHA. Training on the applicable standards must be provided during work hours and at no cost to the worker. See Training Requirements in OSHA Standards. 

Bloodborne Pathogens Standard: Employers must ensure that all workers with occupational exposure in the office participate in a training program. Training on bloodborne pathogens must be provided to employees with occupational exposure to bloodborne pathogens:

• At the time of initial hire
• Annually, within one year of the employee’s previous training.
• When changes such as modification of tasks or procedures, or institution of new equipment, tasks, or procedures affect the worker's occupational exposure – this additional training may be limited to addressing the new exposures created.
• Within 90 days after the effective date of the standard and for workers who have received training on bloodborne pathogens in the year preceding the effective date of the standard, only training with respect to the provisions of the standard which were not included need be provided.

Hazard Communication Standard: Training must be provided on this standard and additional training provided when introducing new hazards into the office that are covered by the Hazard Communication Standard.

Exposure Control Plan

OSHA requires that employers in private dental settings (and applicable public dental settings) must have a written exposure control plan. Your exposure control plan must be accessible for all employees, and on request, employees must be able to receive a copy of this. Employers must review its location during training.  

The exposure control plan's overall goal is to identify potential occupational exposure to bloodborne pathogens and describe the methods that are and will be used in the dental setting (i.e., the specific dental office) to prevent exposure.

Content Requirements
The following must be included in your exposure control plan:

• Determination of employee exposure (a list of who and which jobs have occupational exposure, and during which tasks and procedures)
• Safe work practices and methods of implementation and control (e.g., PPE, engineering and work practice controls, universal precautions)
• Hepatitis B vaccination
• Communication of hazards to employees and training
• Post-exposure evaluation and follow-up
• Recordkeeping (training records on BBP Standard, medical records, declination of Hep B vaccination, OSHA recordkeeping, sharps injury log)
• A list and description of procedures for evaluating exposure circumstances.

Executing an Exposure Control Plan
Each office must have an exposure control plan. Sample plans are available on the OSHA website (Sample Bloodborne Pathogens Exposure Control Plan). The exposure control plan has sections where all of the content requirements are addressed in a practical and logical manner. After completing the exposure control plan, this must be reviewed and updated annually. Employers must review its content and location during training.  

Authorized OSHA Outreach Training Program Trainer Designation

To become an OSHA Outreach Training Program trainer, an individual must meet the prerequisites and complete the applicable industry trainer course through an Authorizing Training Organization (ATO). See the specific industry program procedures for detailed information. Trainer course prerequisites include components for both industry-specific safety and health experience and training in OSHA standards for that industry. These are separate components. Industry experience cannot be used to fulfill or replace the training prerequisite component. OSHA does not waive the training prerequisite component.

Note: The OSHA Outreach Training Program is not a certification program and must not be advertised as such.

Resources

Occupational Safety and Health Administration (OSHA)

• Coronavirus Disease (COVID-19)
• Fact Sheets
• Frequently cited OSHA Standards
• Guide to Compliance with OSHA Standards for Medical & Dental Offices
• Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers
• Hepatitis B Declination Statement
• How to Plan for Workplace Emergencies and Evacuations
• Injury and Illness Recordkeeping and Reporting Requirements
• Inspections (Establishment Search)
• Job Safety and Health: It’s the Law poster
• Model Plans and Programs for the OSHA Bloodborne and Hazard Communication Standards
• Occupational Noise Exposure
• Outreach Training Program (OSHA 10-Hour & 30-Hour Cards)
• Personal Protective Equipment
• Hospital Respiratory Protection Program Toolkit
• Respiratory Protection
• Safety and Health Topics - Dentistry
• Sample Bloodborne Pathogens Exposure Control Plan
• State Plans
• Training Requirements and Resources
• Workers’ Rights

National Institute for Occupational Safety and Health (NIOSH)

• Health Hazard Evaluation Program

Association for Dental Safety (ADS), formerly known as the Organization for Safety, Asepsis and Prevention (OSAP)

• Agency Resources
• Frequently Asked Questions (FAQs)
• Toolkits & Topics
• OSHA & CDC Guidelines: OSAP Interact Training System 7th Edition workbook