guide
OSHA requirements for dental offices
The core OSHA requirements for dental offices are a written exposure control plan 29 CFR 1910.1030(c)(1)(i), bloodborne pathogens training at least once a year 29 CFR 1910.1030(g)(2)(ii), and a written hazard communication program 29 CFR 1910.1200(e)(1). This guide lists each requirement, the rule that asks for it, how often it is due, and who does it.
OSHA says: "There are currently no specific OSHA standards for dentistry." The general industry standards apply instead osha.gov/dentistry. One of them is the bloodborne pathogens standard, which names "saliva in dental procedures" as potentially infectious material 29 CFR 1910.1030(b). This guide covers the federal rules. Some states run their own plans; see the states.
39 requirements
Every requirement at a glance
What does the bloodborne pathogens standard require?
A written exposure control plan, reviewed at least once a year 29 CFR 1910.1030(c)(1)(iv); protective equipment at no cost 29 CFR 1910.1030(d)(3)(i); the hepatitis B vaccine and follow-up after an exposure incident 29 CFR 1910.1030(f)(1)(i); training at initial assignment and each year 29 CFR 1910.1030(g)(2)(ii); training records kept 3 years 29 CFR 1910.1030(h)(2)(ii); and medical records kept for the length of employment plus 30 years 29 CFR 1910.1030(h)(1)(iv).
Written exposure control plan
Each employer with an employee who has occupational exposure must have a written plan to eliminate or minimize that exposure. The plan contains the exposure determination, the schedule and method for the other parts of the rule, and the procedure for evaluating an exposure incident.
Review and update the plan, document safer medical devices
Review and update the plan at least once a year, and whenever new or changed tasks, procedures or positions affect exposure. Each review reflects new technology that reduces exposure and documents the safer medical devices you considered and put in use.
Ask frontline patient-care staff for input on safer devices, document it
Ask non-managerial staff who give direct patient care, and who may be injured by contaminated sharps, for input on engineering and work practice controls. Record that you asked in the plan.
Exposure determination (job classes and tasks)
List the job classifications in which all employees have occupational exposure, those in which some do, and the tasks and procedures with exposure. Make the list without regard to protective equipment.
Plan copy accessible to employees
Staff must be able to get a copy of the plan. You must also give it to OSHA on request.
Universal precautions, engineering and work practice controls
Observe universal precautions to prevent contact with blood and other potentially infectious material. In dental work, saliva counts as such material. Use engineering and work practice controls first, and protective equipment where exposure remains. Provide handwashing facilities, and keep eating, drinking and cosmetics out of work areas where exposure is likely.
29 CFR 1910.1030(d)(1)29 CFR 1910.1030(b)29 CFR 1910.1030(d)(2)(i)29 CFR 1910.1030(d)(2)(iii)29 CFR 1910.1030(d)(2)(ix)
No bending, recapping or removing contaminated needles, unless a dental procedure requires it and it is done with a device or one hand
Do not bend, recap or remove contaminated needles or other sharps, unless no alternative is feasible or a specific dental procedure requires it. Then use a mechanical device or a one-handed technique. Never shear or break contaminated needles.
PPE at no cost, in correct sizes
Provide gloves, gowns, masks, eye protection and similar equipment at no cost, in the right sizes, with glove alternatives for staff who are allergic. Clean, launder and dispose of it at no cost. Wear masks with eye protection, or chin-length face shields, when splashes or spray may reach the eyes, nose or mouth.
29 CFR 1910.1030(d)(3)(i)29 CFR 1910.1030(d)(3)(iii)29 CFR 1910.1030(d)(3)(iv)29 CFR 1910.1030(d)(3)(x)
Written cleaning and decontamination schedule
Write a schedule for cleaning and the method of decontamination for each area. Decontaminate work surfaces after procedures, right after a spill, and at the end of the shift if they may be contaminated.
Biohazard labels or red bags/containers
Put warning labels on regulated waste containers and on refrigerators and freezers that hold blood or other potentially infectious material. The labels are fluorescent orange or orange-red. Red bags or red containers may replace labels.
29 CFR 1910.1030(g)(1)(i)(A)29 CFR 1910.1030(g)(1)(i)(C)29 CFR 1910.1030(g)(1)(i)(E)
Hepatitis B vaccine at no cost
Make the vaccine available at no cost, at a reasonable time and place, after the training and within 10 working days of initial assignment. You cannot require a prescreening program first. An employee who declines can accept the vaccine later.
29 CFR 1910.1030(f)(1)(ii)29 CFR 1910.1030(f)(2)(i)29 CFR 1910.1030(f)(2)(ii)29 CFR 1910.1030(f)(2)(iii)
Signed declination statement (exact Appendix A text)
An employee who declines the vaccine signs the statement in Appendix A, with its exact wording.
Post-exposure evaluation and follow-up
After an exposure incident is reported, make a confidential medical evaluation and follow-up immediately available, at no cost. It includes documentation of the route and circumstances, identification of the source individual where feasible, blood testing, preventive treatment when medically indicated, counseling, and evaluation of reported illnesses.
Healthcare professional's written opinion to employee
Get the evaluating healthcare professional's written opinion and give the employee a copy within 15 days of the end of the evaluation.
Bloodborne pathogens training
Train each employee with occupational exposure at no cost and during working hours: at initial assignment, then within one year of the previous training, and again when new tasks or procedures change their exposure.
29 CFR 1910.1030(g)(2)(i)29 CFR 1910.1030(g)(2)(ii)29 CFR 1910.1030(g)(2)(iv)29 CFR 1910.1030(g)(2)(v)
Live Q&A with a knowledgeable trainer
Training includes live questions and answers with a trainer who knows the subject as it relates to your office. With online training, the trainer must be available at the time questions arise, in person, by phone or by live video.
29 CFR 1910.1030(g)(2)(vii)(N), (viii)OSHA letter 2003-06-26OSHA letter 2008-01-17OSHA letter 1999-01-15
Training records
Each record holds the dates, the content or a summary, the names and qualifications of the trainers, and the names and job titles of the people trained. Keep it 3 years from the training date. Give it to employees and OSHA on request.
29 CFR 1910.1030(h)(2)(i)29 CFR 1910.1030(h)(2)(ii)29 CFR 1910.1030(h)(3)(ii)
Medical records (confidential)
Keep a confidential medical record for each employee with occupational exposure, including hepatitis B vaccination status and dates. Keep it for the length of employment plus 30 years.
29 CFR 1910.1030(h)(1)(ii)29 CFR 1910.1030(h)(1)(iii)29 CFR 1910.1030(h)(1)(iv)
What does hazard communication require in a dental office?
A written program with a list of the hazardous chemicals present 29 CFR 1910.1200(e)(1), a safety data sheet for each one that staff can reach during each shift 29 CFR 1910.1200(g)(8), labels on containers 29 CFR 1910.1200(f)(6), and training at initial assignment and when a new chemical hazard comes in 29 CFR 1910.1200(h)(1). Updates under the 2024 rule, "as necessary", are due no later than November 20, 2026 for substances 29 CFR 1910.1200(j)(2)(ii).
Written hazard communication program with chemical list
Write a program that describes how you meet the rules for labels, safety data sheets and training. It includes a list of the hazardous chemicals present, by product identifier. Give it to employees and OSHA on request.
29 CFR 1910.1200(e)(1)29 CFR 1910.1200(e)(1)(i)29 CFR 1910.1200(e)(4)
Workplace container labels
Each container of a hazardous chemical has a label with the product identifier and its hazards. A portable container filled for immediate use by the person who fills it is exempt from labeling. Do not deface incoming labels. Labels are in English.
29 CFR 1910.1200(f)(6)29 CFR 1910.1200(f)(8)29 CFR 1910.1200(f)(9)29 CFR 1910.1200(f)(10)
Safety data sheet for each hazardous chemical, accessible every shift
Have a safety data sheet for each hazardous chemical you use. Staff must be able to reach them during each shift. Electronic access is allowed if staff keep immediate access.
Hazard communication training
Train staff at initial assignment and whenever a new chemical hazard comes into their work area. Training covers how to detect a release, the hazards, how to protect yourself, and the details of your program.
Hazard communication updates under the 2024 rule
The updated rule took effect July 19, 2024. For substances, employers update alternative workplace labels, the program and training "as necessary" no later than November 20, 2026. For mixtures, the date is May 19, 2028.
29 CFR 1910.1200(j)(1)29 CFR 1910.1200(j)(2)(ii)29 CFR 1910.1200(j)(3)(ii)
What do the emergency and fire rules require?
Where the office has portable fire extinguishers, inspect them visually each month 29 CFR 1910.157(e)(2) and have a maintenance check once a year, with the date recorded 29 CFR 1910.157(e)(3). You need an emergency action plan or a fire prevention plan when an OSHA standard requires one 29 CFR 1910.38(a) 29 CFR 1910.39(a). The free emergency action plan template explains each plan.
Emergency action plan
You need an emergency action plan when an OSHA standard requires one. It is in writing, kept in the office and available to staff. An office with 10 or fewer employees may give it orally. It covers how to report an emergency, evacuate, account for everyone, and who to contact about the plan.
Review the emergency action plan with each employee
Review the plan with each employee when it is made or when they start, when their duties under it change, and when the plan changes. Also designate and train staff to help with a safe evacuation.
Employee alarm system
Have and maintain an employee alarm system with a distinctive signal for each purpose.
Fire prevention plan
You need a fire prevention plan when an OSHA standard requires one. It is in writing, kept in the office and available to staff. An office with 10 or fewer employees may give it orally. It lists the major fire hazards and their controls, and who maintains the equipment.
Tell employees their fire hazards
Tell each employee the fire hazards they are exposed to when they start, and review the parts of the plan they need for self-protection.
Fire extinguisher visual inspection
Inspect portable fire extinguishers visually each month. If extinguishers are not meant for staff use and you have both plans, the extinguisher rule shrinks to inspection, maintenance and testing.
Fire extinguisher maintenance check, record kept
Have each extinguisher checked once a year. Record the date and keep the record for one year after the last entry or the life of the shell, whichever is less.
Fire extinguisher training
If staff are meant to use the extinguishers, teach the general principles of extinguisher use and the hazards of fighting an early-stage fire, at hire and once a year.
Does a dental office need an eyewash station?
Yes, where the eyes or body may be exposed to injurious corrosive materials: the office provides facilities for quick drenching or flushing in the work area 29 CFR 1910.151(c). With no infirmary, clinic or hospital nearby, a person trained in first aid and adequate first aid supplies are required 29 CFR 1910.151(b). For protective equipment, use the free PPE hazard assessment form.
Eyewash or drench facility
Where the eyes or body may be exposed to injurious corrosive materials, provide a facility for quick drenching or flushing within the work area.
First aid trained person and supplies
If no infirmary, clinic or hospital is near the office, have a person trained in first aid. Keep adequate first aid supplies readily available.
PPE hazard assessment with written certification
OSHA requires a written PPE hazard assessment certification for eye, face, hand and other PPE covered by 1910.133-1910.138.
PPE training
Train each employee who must use that PPE: when it is needed, what is needed, how to put it on and take it off, its limits, and its care. Each person shows they understand before the work. Retrain when someone does not.
29 CFR 1910.132(f)(1)29 CFR 1910.132(f)(2)29 CFR 1910.132(f)(3)
Does a dental office need to post the OSHA poster?
Yes. Every employer posts the OSHA poster where notices to employees are usually posted 29 CFR 1903.2(a)(1), and the poster is free from OSHA. Each exit is marked by a sign reading "Exit" 29 CFR 1910.37(b)(2). The ionizing radiation rule also applies if you have x-ray equipment 29 CFR 1910.1096(d).
OSHA poster (OSHA 3165), or state plan poster
Post the OSHA Job Safety and Health poster where notices to employees are usually posted. It is free from OSHA, and an older version is fine. A state plan may have its own approved poster.
29 CFR 1903.2(a)(1)29 CFR 1903.2(a)(2)osha.gov/publications/poster
Exit signs
Each exit must be clearly visible and marked by a sign reading “Exit.”
X-ray radiation surveys and monitoring
The ionizing radiation rule also applies if you have x-ray equipment. It asks for the surveys needed to comply, and for monitoring equipment based on dose.
Check your own office against these rules with the free OSHA self-check, or print a hepatitis B declination form.