Dental OSHA compliance checklist (free printable)

How to use this checklist

Go through it once a year, at the same time as your exposure control plan review. Check the training and vaccine items whenever you hire someone, and the hazard communication items whenever a new chemical comes into the office. Write the date and your name at the top of the PDF and keep it with your OSHA records.

Open the printable version or use the download button.

Bloodborne pathogens (29 CFR 1910.1030)

This standard covers most of what OSHA expects from a dental office.

Exposure control plan

• A written exposure control plan that employees can get to.
• Reviewed and updated at least annually, and whenever tasks or procedures change.
• The yearly review documents that you considered commercially available safer medical devices, such as safer needles and scalpels.
• The review documents input from non-managerial staff who give patient care, such as hygienists and assistants.

Start from the free exposure control plan template.

Training and vaccine

• Bloodborne pathogens training when someone starts tasks with exposure, then within one year of their last session. Details in OSHA training for dental offices.
• The hepatitis B vaccine offered within 10 working days of initial assignment, at no cost. Anyone who declines signs the hepatitis B vaccine declination form.

Controls and PPE

• Engineering and work practice controls used to eliminate or minimize exposure, with PPE where exposure remains.
• Gloves, masks, eye protection and gowns provided at no cost, readily accessible, and cleaned, repaired, replaced or disposed of by the office.
• Contaminated needles are not bent, recapped or removed unless no alternative is feasible or the procedure requires it, and then only with a mechanical device or a one-handed technique.

Sharps, waste and cleaning

• Sharps containers that are closable, puncture resistant, leakproof on the sides and bottom, and labeled or color-coded. Kept upright and easy to reach while in use, replaced routinely and never overfilled.
• Regulated waste in closable, leakproof containers that are labeled or color-coded and closed before removal.
• A written cleaning and decontamination schedule for each area, based on the surfaces and the tasks done there.
• Warning labels with the biohazard symbol, fluorescent orange or orange-red, on containers of regulated waste and contaminated items.

After an exposure incident

• A confidential medical evaluation and follow-up made available to the employee immediately. It covers how the exposure happened, testing of the source individual where possible, testing of the employee's blood, preventive treatment when indicated, and counseling.
• A copy of the healthcare professional's written opinion given to the employee within 15 days of the evaluation.

Records

• Training records kept 3 years from the date of training.
• Employee medical records, including hepatitis B vaccination status, kept for the duration of employment plus 30 years, confidentially.

Hazard communication (29 CFR 1910.1200)

Dental offices use disinfectants, x-ray chemicals, etchants, alloys and other products that count as hazardous chemicals.

• A written hazard communication program that explains how you handle labels, safety data sheets and training.
• A list of the hazardous chemicals in the office, by product identifier.
• A safety data sheet for each hazardous chemical, readily accessible to employees during every shift. Electronic access is allowed if it doesn't get in the way of immediate access.
• Every container labeled, including spray bottles and other containers you fill in the office. The one exception is a portable container meant only for immediate use by the person who filled it.
• Training at initial assignment and whenever a new chemical hazard is introduced.

Consumer products used the way a consumer would use them, and drugs in solid final form given directly to a patient, are exempt.

PPE hazard assessment (29 CFR 1910.132)

• A hazard assessment of the workplace to decide which PPE each task needs.
• A written certification that the assessment was done. It names the workplace, the person who certified it and the date, and says it is a certification of hazard assessment.
• PPE training: when PPE is needed, which PPE, how to put it on, take it off, adjust and wear it, its limits, and how to care for and dispose of it.

Exits, emergency plans and fire safety

• Exit routes free and unobstructed. Each exit marked by a sign reading "Exit", and each route lit well enough to see along it (1910.37).
• An emergency action plan (1910.38) and fire prevention plan (1910.39) where an OSHA standard requires them. Offices with 10 or fewer employees may communicate them orally. Review the emergency action plan with each employee at initial assignment, when their duties under it change and when the plan changes.
• Fire extinguishers mounted, identified and readily accessible, visually inspected monthly, with an annual maintenance check recorded (1910.157).
• If staff are expected to use the extinguishers, training at hire and at least annually. An office with a written total evacuation policy and no extinguishers for employee use has fewer requirements under this standard.

First aid, eyewash and posters

• Eyewash or drench facility within the work area wherever eyes or body may be exposed to injurious corrosive materials (1910.151(c)). Check your safety data sheets to see if any of your chemicals are corrosive.
• The OSHA workplace poster displayed where employees can see it (1903.2). It is free from OSHA. If your state runs a State Plan, post the state version.

Injury recordkeeping and reporting

• Offices of dentists (NAICS 6212) are partially exempt from keeping the OSHA 300 injury and illness log. Companies with 10 or fewer employees during all of the last calendar year are exempt too. Either way, OSHA or the Bureau of Labor Statistics can ask you in writing to keep records.
• Every employer must report to OSHA a work-related fatality within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (1904.39).
• The sharps injury log applies only to employers required to keep the 300 log, so most dental offices don't need one. Follow the post-exposure steps for every incident regardless.

X-ray equipment

OSHA's ionizing radiation standard (1910.1096) requires that people working in a radiation area are told about the radiation, its hazards and the precautions to take, and that a former employee who asks for their exposure report gets it in writing within 30 days. Your state radiation control program may also have rules for dental x-ray equipment, so check with it.

State Plan states

Twenty-two states and territories run OSHA-approved State Plans that cover private employers such as dental offices. Their rules must be at least as effective as federal OSHA and can be stricter, and some have their own poster. If your office is in a State Plan state, check its version of each item.

Inspection day: documents to have ready

An inspector will ask to see how you meet the standards above. Keep these in one place, on paper or in an app:

1. The exposure control plan, with the date of its last yearly review and the safer device and staff input notes.
2. Bloodborne pathogens training records for the last 3 years: dates, content, trainer and attendees.
3. Hepatitis B vaccine records and signed declinations for each employee with exposure.
4. The written hazard communication program, the chemical list and the safety data sheets.
5. The signed PPE hazard assessment certification.
6. The emergency action and fire prevention plans, if written, and the fire extinguisher inspection and maintenance records.
7. The written cleaning and decontamination schedule.
8. Post-exposure records for any exposure incidents.

Sterilizer and spore test records come from CDC guidelines and state dental board rules, not OSHA, but keep them with the rest so a dental board investigator can see them too. Use the free autoclave log sheet. HIPAA is a separate set of rules; see HIPAA compliance for dental offices. ComplyDay covers both with OSHA and HIPAA training for dental offices and the records behind them.