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COVID-19 prevention regulations apply to fully vaccinated dental patients, staff until Cal/OSHA amends regulations

Cal/OSHA enforcing annual test requirements for tight-fitting respirators

March 24, 2021 9459

Quick Summary:

Dental offices must continue to screen all patients and dental staff, including those who are fully vaccinated, for COVID-19 and follow other Cal/OSHA regulations on COVID-19 prevention, such as using proper personal protective equipment and requiring that patients wear masks and socially distance.

The California Division of Occupational Safety and Health’s current regulations on COVID-19-related screening, testing and quarantining apply to dentists, dental team members and other health care workers in California who are fully vaccinated against the novel coronavirus, as well as to fully vaccinated patients who enter health care settings.

Dental offices, therefore, must continue to screen all patients and dental staff, including those who are fully vaccinated, for COVID-19 and follow other Cal/OSHA regulations on COVID-19 prevention, such as using proper personal protective equipment and requiring that patients wear masks and socially distance, until Cal/OSHA amends its COVID-19 regulations. These infection prevention procedures must be documented in a written plan, as required by Cal/OSHA.

Following an uptick in vaccine supply and administration, news outlets earlier this month widely reported the U.S. Centers for Disease Control and Prevention’s interim public health recommendations for fully vaccinated individuals. The CDC considers a person fully vaccinated if more than two weeks have passed since they received a single-dose vaccine, like the Janssen COVID-19 Vaccine by Johnson & Johnson, or the second in a two-dose vaccine series.

But the news created confusion both for health care workers and patients seeking care because those recommendations are intended only for non-health-care settings and allow fully vaccinated people to refrain from observing social distancing and wearing masks in some situations. They also allow fully vaccinated individuals to refrain from COVID-19 testing and quarantine following exposure to someone with confirmed or suspected COVID-19.

The CDC issued separate recommendations for fully vaccinated individuals in health care settings, and those recommendations more closely align with current Cal/OSHA regulations. Cal/OSHA expects to update its regulations to address exposure protocols for fully vaccinated employees later this year. Until then, dental practices should continue to:

  • Screen all patients and staff for COVID-19 and record employees’ COVID-19 symptoms, exposure or positive test, regardless of whether the employee was exposed in the dental office (CDA has a tracking form)
  • Ask fully vaccinated staff who have had close contact with someone who tested positive for or has symptoms of COVID-19 to quarantine
  • Ensure six feet of physical distancing
  • Provide employees with proper personal protective equipment, including respirators for aerosol generating procedures
  • Follow all other Cal/OSHA COVID-19 prevention regulations  

Cal/OSHA will enforce annual fit requirements for tight-fitting respirators

Medical evaluation and fit testing is a Cal/OSHA requirement for use of most respirators, including the N95. Employers are required to provide an initial fit test and an annual fit test. “Annual” means one year from the last fit test for the specific model being used.

Although OSHA temporarily suspended the annual fit test in April 2020 due to the public health crisis, Cal/OSHA announced it would continue enforcing the annual fit-test requirement. The agency will allow a 90-day delay for meeting annual fit-testing requirements provided there are no changes in an employee's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery or an obvious change in body weight.

Fit testing is a two-step process that is usually performed by two different entities: The medical evaluation occurs first and is followed by the actual fit test. A licensed health care professional must perform the medical evaluation using a questionnaire to gather specific required information. 

Dental practices that do not receive consistent shipments of the types and sizes of respirators they ordered should document those events. Cal/OSHA only considers NIOSH-certified respirators, such as N95s, as appropriate protection when respiratory protection is required in the dental office.

The CDA Practice Support resource N95 Fit Testing Requirements explains how to locate a medical evaluator and fit tester and all the steps required as part of the fit test.