The Cal/OSHA COVID-19 Prevention Non-Emergency Regulations that took effect in 2023 expired Feb. 3, 2025, with one exception: employers’ reporting and recordkeeping requirements will remain in effect through Feb. 3, 2026.
Dental practices in California followed the regulations, which required employers to document COVID-19 as a workplace hazard either by implementing a written COVID prevention plan or by adding a COVID addendum to the practice’s existing injury and illness prevention plan. (CDA provided a sample addendum for members’ use.) They also followed specific isolation and exposure protocol.
COVID-19 prevention plan/IIPP addendum no longer required
With the nonemergency regulations’ expiration, practice owners in California are no longer required to have a COVID prevention plan or addendum to the IIPP but must continue to comply with the Injury and Illness Prevention Program if they are exempt from Cal/OSHA’s regulation on aerosol transmissible diseases. Most dental practices are exempt if they comply with specific conditions. Those that are not exempt must follow the ATD regulation. (See CDA’s Cal/OSHA Regulation on Aerosol Transmissible Diseases.)
California dental practices should follow CDPH’s interim guidance (Jan. 10, 2025) for excluding employees with COVID-19, influenza and other acute respiratory viral infections.
COVID reporting and recordkeeping requirements
Employers’ reporting and recordkeeping requirements described in section (j) of the nonemergency regulation will end Feb. 3, 2026. In summary, the requirements are:
- Track and record all employee COVID records with the employee’s name and other specific information for the required period.
- Retain the notices listed in subsection 3205(e) as required.
- Maintain the confidentiality of personal identifying information in COVID cases unless the law requires or permits disclosure.
- Provide unredacted information on COVID cases to the local health department with jurisdiction over the workplace, California Department of Public Health and NIOSH immediately upon request and when required by law.