Cal-OSHA Injury Illness Prevention Dental Practice or Lab Requirements

Cal-OSHA requires every employer in the state of California to establish, implement and maintain an effective Injury and Illness Prevention Program.

This Program should be in writing and available to employees.  This Program requires the employer to conduct scheduled and periodic inspections to identify unsafe conditions and work practices.  Records of those inspections are to be retained for at least one year.  An exception for employers with fewer than 10 employees allows for that employer to maintain the inspection records only until the hazard is corrected. 

There are other exceptions that would apply to a dental practice but not to a dental laboratory in regard to the written documentation.  Dental laboratories remain on the high-hazard industry list at this time so this recordkeeping and other injury and illness recordkeeping requirements continue to apply to dental laboratories. 

The California Code of Regulations, Title 8, Section 3205 addresses COVID-19 prevention.  This Order details Cal-OSHA’s expectations for compliance.  Either a separate written document, such as an Infectious Disease Prevention and Response Plan, can be developed or the Injury and Illness Prevention Program can be expanded to include COVID-19 prevention.  SafeLink’s Infectious Disease Preparedness and Response Plan is specific to the Cal-OSHA requirements if you need assistance in complying with this CA state requirement. 

California also addresses Aerosol Transmissible Diseases in the CA Code of Regulations Title 8, Section 5199. This standard applies to employers that have employees with occupational exposure, defined as “exposure from work activity or working conditions that is reasonably anticipated to create an elevated risk of contracting any disease caused by ATPs or ATPs-L if protective measures are not in place.”  Some employers must comply with the full standard and others are only required to comply with certain parts.   

Section 5199 indicates that the following are NOT covered by this standard: 

Outpatient dental clinics or offices if they meet ALL of the following conditions:

• Dental procedures are not performed on patients identified to them as ATD cases or suspected ATD cases. 
• The Injury and Illness Prevention Program includes a written procedure for screening patients for ATDs that is consistent with current guidelines issued by the Centers for Disease Control and Prevention for infection control in dental settings, and this procedure is followed before performing any dental procedure on a patient to determine whether the patient may present an ATD exposure risk. 
• Employees have been trained in the screening procedure in accordance with Section 3203. 
• Aerosol generating dental procedures are not performed on a patient identified through the screening procedure as presenting a possible ATD exposure risk unless a licensed physician determines that the patient does not currently have an ATD.” 

Needless to say, in the State of California, dental practices and dental laboratory technicians who provide direct patient services must continue the patient screening procedure in order to maintain this exemption.  Dental practices and dental laboratories in other states need to follow the requirements in their state as well.  If you need assistance in determining if OSHA in the state you’re located in has any specific requirements, please contact us. 

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Learn more about what SafeLink Consulting can do to help your business with compliance services, including safety compliance, to meet OSHA training requirements and quality system consulting to meet FDA compliance.  SafeLink Consulting assists businesses with workplace safety training, infection control training, HIPAA training online, quality systems, assessments, audits, due diligence, and more.

Industries include:

Dentistry compliance - assisting the dental practice with meeting requirements for OSHA, HIPAA, EPA, and CDC guidelines, patient safety and employee health & safety

Dental Laboratory compliance - assisting the dental lab with meeting requirements for OSHA, FDA, and CDC guidelines, employee health & safety, plus FDA requirements for lab manufacturing custom implant abutment /gmp for medical device manufacturers

Medical Device Manufacturers compliance - assisting with meeting OSHA compliance & FDA requirements, GMP - good manufacturing practices

General Industry compliance - assisting with OSHA compliance and FDA compliance as it pertains to the specific business

Beverage Industry compliance - assisting beverage businesses such as the craft brewery, winery, cidery, distillery, vintner with meeting OSHA compliance, health & safety, FDA requirements / GMP - Good Manufacturing Practices.