Do dental assistants and hygienists need bloodborne pathogens training?

OSHA applies to dental offices

OSHA has no dentistry-specific standard, so dental offices follow the general industry rules. Its compliance guide for medical and dental offices calls the bloodborne pathogens standard, 29 CFR 1910.1030, the standard most often referenced for those offices.

The standard covers employees who can reasonably expect contact with blood or other potentially infectious materials. In dentistry, saliva counts as potentially infectious material, so chairside work, instrument processing and handling sharps all create occupational exposure.

Who on the team needs it

Dental assistants, hygienists, associate dentists and sterilization technicians who are employees need the training. A front desk employee needs it if the job includes exposure tasks such as helping in the operatory, turning over rooms or handling instruments. A receptionist who only schedules and bills does not.

A practice owner who is not an employee has no OSHA training obligation for themselves, but must train every employee with exposure.

What the practice owes each employee

Training at no cost during working hours, when first assigned to exposure tasks and within one year of the previous training (paragraph (g)(2)). The training must give the employee a chance to ask questions of someone knowledgeable about the material ((g)(2)(vii)(N)).

The hepatitis B vaccine, offered at no cost after training and within 10 working days of initial assignment ((f)(2)(i)). Employees may decline in writing.

A written exposure control plan, reviewed at least once a year. The review must consider safer sharps devices and get input from the staff who use them ((c)(1)(iv) and (v)).

Records to keep

Keep training records for three years from the training date: the dates, a summary of the content, the trainer's name and qualifications, and the names and job titles of everyone trained ((h)(2)).

State dental board courses are separate

Some states require their own infection control course for dental staff, set by the dental board rather than OSHA, and usually from a board-approved provider. California requires an unlicensed dental assistant, before any procedure with potential exposure to blood or saliva, to pass the Dental Assisting National Board's Infection Control exam or complete an infection control course the statute lists (a board-approved eight-hour course, or at least four hours of instruction and two of lab from a CDA, ADA CERP or AGD PACE provider, which may be online). New York requires dentists and dental hygienists to complete state-approved infection control and barrier precautions coursework every four years.

A general bloodborne pathogens course does not satisfy those state board requirements, and those board courses do not replace the annual OSHA training unless they cover the standard's required topics and the practice's own exposure control plan. Check your state dental board's rules.

Training the whole office

Bloodborne Cert sells seats for any number of staff. Each person trains on their own time, and one page shows who has finished, their certificate numbers and their retrain dates. Add your site-specific information, such as where the exposure control plan is kept and your post-exposure procedure, and name a person staff can ask questions.

Dental offices also need HIPAA training for staff who handle patient information. Bloodborne Cert sells a HIPAA Privacy and Security course and a bundle with both courses.