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Infection Control

Official Guidance

From the CDPH

Released May 7, updated guidance for resuming deferred and preventive dental care.

View CDPH Guidance

Official Guidance

From the CDC

Updated December 4, interim infection prevention and control guidance for dental settings during the COVID-19 response.

View CDC Guidance

Employers requiring respirators must establish a respiratory protection program

Dentists can customize CDA Practice Support's respiratory protection program template

CDA Practice Support is fielding many questions from members about the requirements related to use of N95 masks and other respirators in the dental practice. Many members specifically are inquiring whether they are obligated to establish a respiratory protection program given the ongoing N95 supply challenges.

They are required to do so, in addition to providing an initial fit test.

The state guidance issued May 7 for resuming deferred and preventive dental care states that employers of dental health care personnel are “responsible for following applicable OSHA requirements, which include Cal/OSHA’s bloodborne pathogens, personal protective equipment, and respiratory protection standards.”

Both the Occupational Safety and Health Administration and Cal/OSHA require employers to establish a respiratory protection program whenever the employer requires its employees to wear a respirator for protection. Dental personnel are included in that group.

Following OSHA’s current guidance for dentistry, dental personnel should wear N95 respirators when performing aerosol-generating procedures on all patients who are “well,” that is do not have confirmed or suspected COVID-19, the respiratory illness caused by the new coronavirus. More stringent PPE is required for patients who have known or suspected COVID-19. (See the “Personal Protective Equipment” table in the guidance.)

If N95 or equivalent respirators are not available, dentists should not perform aerosol-generating procedures unless the patient requires emergency treatment. Dental practices should have a two-week supply of PPE, among other supplies, before they reopen to provide deferred and preventive care, according to the state guidance.

Respiratory protection program template available to CDA members

Dental practice owners can use CDA Practice Support’s respiratory protection program template, which is part of CDA’s Regulatory Compliance Manual. The downloadable document provides an overview of the program and describes the requirements related to:

  • Respiratory selection
  • Medical evaluations (required for each covered employee)
  • Fit testing
  • Use of respirators
  • Maintenance and care of respirators
  • Employee training
  • Program evaluation

Initial respirator fit testing required

Dentist employers should understand that although the required annual fit testing requirement has been temporarily suspended, they are still required to provide the initial fit test for each employee who is required to wear a respirator.

Fit testing is a two-step process that is usually performed by two different entities: First is the medical evaluation, which is followed by the actual fit test.

Dental employers will learn how to locate a medical evaluator and a fit tester by reviewing the N95 Respirator/Mask Information resources developed by CDA’s Clinical Care Workgroup to help dentists get back to practice. Staff training on respirator use also is required.

Resources cited in this article and additional guidance:
CDA Practice Support’s Respiratory Protection Program template
CDA’s N95 Respirator/Mask Information page
CDA’s Regulatory Compliance: Respirators and Fit Testing
OSHA statement on enforcement memorandum on fit testing
CDPH guidance for dental health care personnel on resuming deferred and preventive care
ADA on-demand webinar about respiratory protection