The OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to all dental practices with employees who may encounter blood or other potentially infectious materials. Non-compliance carries penalties up to $15,625 per violation, and inspections do occur.

Training Requirements

Initial training must occur before an employee begins duties with occupational exposure risk. Annual retraining is required thereafter, within 12 months of previous training. Training must be interactive and allow questions. A video alone does not satisfy the standard.

Required content includes: explanation of bloodborne pathogens and their transmission, review of the Exposure Control Plan, hepatitis B vaccination information, emergency procedures following exposure incidents, and explanation of signs, labels, and color coding.

Common Compliance Gaps

The most frequent citation involves inadequate documentation. Training records must include date, content summary, trainer qualifications, and attendee signatures. Records must be maintained for three years after training.

Another common gap: failing to update training when new procedures or equipment are introduced. If your practice adopts new safety devices or protocols, supplemental training is required. The annual cycle alone does not cover mid-year changes.

Exposure Control Plan

Every dental practice must have a written Exposure Control Plan reviewed and updated annually. The plan must identify job classifications with occupational exposure, describe vaccination programs, and detail post-exposure evaluation procedures.

OSHA provides model Exposure Control Plans for dental practices on its website. These templates require customization to reflect your specific practice procedures and can serve as compliance foundations.

Documentation Best Practices

Maintain training records in a dedicated compliance folder with signed attendance sheets, training agendas, and presenter credentials. Digital records are acceptable but must be readily retrievable during inspections.

Consider scheduling annual training during the same month each year to avoid lapses. Automated reminders help maintain compliance when staff turnover creates irregular training schedules.