Enforcement

This section highlights OSHA directives (instructions for OSHA's compliance safety and health officers) and some selected letters of interpretation (official letters of interpretation of the OSHA's standards) related to dentistry.

Directives

• Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard, 29 CFR 1910.1030. CPL 02-02-069 [CPL 2-2.69], (November 27, 2001). Establishes policies and provides clarifications to ensure uniform inspection procedures are followed when conducting inspections to enforce the Occupational Exposure to Bloodborne Pathogens Standard. Dentists, dental hygienists, dental assistants and dental laboratory technicians are job classifications that may be associated with tasks that have occupational exposure to blood and other potentially infectious materials.

Letters of Interpretation

Medical Instruments

• OSHA has no specific standard on autoclaving used medical instruments. (September 3, 2004). Refers to guidelines and recommendations on the use and monitoring of sterilization equipment in dental healthcare settings by the Centers for Disease Control and Prevention (CDC) and the Food and Drug Administration (FDA), which may also have relevant information in connection with that agency's approval of autoclaves, as OSHA has no specific standard.

Bloodborne Pathogens

• Whether dental anesthetic carpules are considered to be "contaminated sharps" or "regulated waste". (January 9, 2007) Discusses dental anesthetic carpules in relation to the Bloodborne Pathogen Standard.
• OSHA's standard of exposure to bloodborne pathogens. (July 3, 1997). Discusses the standard requirement that employees use gloves in the dental setting when there is hand contact with blood or "other potentially infectious material" (OPIM) which includes saliva in dental procedures as well as any body fluid that is visibly contaminated with blood.
• Classification of saliva in dental procedures under the bloodborne pathogens standard. (February 15, 1996). Based upon the recommendations of the CDC with regard to precautions in dentistry and the necessity for assuring employee protection against all bloodborne pathogens, we have concluded that retaining "saliva in dental procedures" as an "other potential infectious material" is appropriate and correct.
• Bloodborne Pathogen standard as it applies to personal protective equipment. (May 6, 1992). Determines that it is the employer's responsibility to evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective clothing in accordance with 29 CFR 1910.1030(d)(3)(i) of the standard. In general, OSHA would expect the employer to select traditional protective clothing, such as clinic jackets, lab coats, or uniforms since this type of clothing is designed to serve as a barrier to strike-through and would protect underlying garments or skin.
• Orthodontics wires considered as "sharps" under CPL 2-2.44D. (May 25, 1990). Determines since the ends of orthodontic wires can penetrate the skin their contamination with blood can reasonably be anticipated. OSHA believes that they must be classified as "sharps" under the above referenced Instruction and standard and disposed of accordingly.

Hazard Communication

• The dental industry's concern regarding compliance with certain provisions of the Hazard Communications Standard. (February 6, 1997). Determined that MSDSs are required for dental devices which are not exempt from coverage under the "article" or "consumer products" provisions of the HCS.
• Overlap between FDA and OSHA in the regulation of dental devices. (January 7, 1997). Conducted a broad hazard determination of the Food and Drug Administration's (FDA's) defined classes of dental devices, and excluded devices that failed to meet the HCS definition of a hazardous chemical. Providestwo tables:
  • The first table identifies "Dental Devices Which Require Manufacturer's Determination for Presence of Hazardous Chemicals and, if Present, Would Then Require a MSDS."
  • The second table identifies "Dental Devices Not Covered by the Hazard Communication Standard."