SHA Guidance for Dentistry
Workers and Employers
OSHA recently issued Guidance for Dentistry Workers and Employers: that information
details recommendations relating to hazard assessments, including the use of respiratory
protection PPE like N95 masks, during aerosol-generating procedures. The agency also
has recommendations regarding performing emergent vs. routine procedures.
How does OSHA’s May 1, 2020, release of Guidance for Dentistry Workers and Employers impact my
practice? Does this new information supersede previous regulations? Are there additional possible
This new Guidance from OSHA does not establish any new requirements and is offered as guidance only.
Guidance documents create no new legal obligations and do not change or establish compliance responsibilities; that
information is detailed in OSHA standards. Standards documents, also known as regulations, are regulatory
requirements that the agency has established and published to serve as criteria for measuring whether employers are
complying with the applicable laws. Employers in all industries, including health care, are compelled to comply with
those applicable OSHA standards that are appropriate to that industry.
What do I need to do to comply with the hazard assessment recommendations in the Guidance? It
recommends that employers assess the hazards that their workers may face; evaluate any risks; and select,
implement and ensure that employees use the controls their employer has implemented to minimize any
risks. How does that translate to changes I need to implement in my practice?
OSHA has had a long standing requirement that employers assess occupational hazards to which their workers may
be exposed. The agency’s Standards for Personal Protective Equipment (PPE) have always required employers to
conduct hazard assessments on the topics of General Requirements and Respiratory Protection.
Some of the factors dentists should consider when conducting a hazard assessment under the new Guidance
the incidence and prevalence of COVID-19 in their area
COVID-19 testing in the area
the aerosol production that will occur during any procedures
available aerosol reduction or mitigation methods, such as use of a rubber dam, availability of high speed
evacuation, alternative treatment measures that might be employed
The ADA is developing a tool to assess an airborne hazard and to help guide dentists through this task. That resource
will be posted on the ADA’s COVID-19 website as soon as it’s available.
Do OSHA regulations require the use of N95 masks during aerosol generating procedures?
The OSHA Respiratory Protection Standard requires that respirators, such as N95 masks, be used any time there is a
respiratory hazard and effective engineering controls are not feasible or while they are being instituted.
If the hazard assessment conducted by an employer dentist determines that workers will be exposed to airborne
contaminants, including aerosols containing SARS-CoV-2, that cannot be mitigated by the systems or controls put in
place to protect them, the employer should consider implementing and following the respiratory protection standard.
According to the Guidance, aerosol-generating procedures performed on patients who are well are considered high
risk procedures and the Guidance recommends, but does not require, that dentistry workers wear N95 masks when
performing those procedures.
The Guidance does require the use of N95 masks any time dentistry workers treat patients who are known to have
tested positive for COVID-19 or who are suspected of having COVID-19. Pre-screening patients for symptoms of
COVID-19, by phone and/or upon arrival for treatment, increases the likelihood those with COVID-19 symptoms will
not be seen and treated. Of course, it’s important to keep in mind some people with COVID-19 remain asymptomatic.
Last Updated: May 13, 2020
OSHA Guidance for Dentistry
Workers and Employers
Are there other requirements when using an N95 mask?
If the hazard assessment determines that the use of an N95 by a dentist or team member is preferred, but not
required, it’s recommended but not required that the person wearing the mask have completed an initial fit test or the
subsequent annual fit test.
Dentists and team members are required to comply with all aspects of OSHA’s respiratory protection program
including the initial and annual fit test, when the hazard assessment determines that the use of an N95 is required. A
seal check must be performed every time an N95 mask is used.
While a number states have announced that dental offices can now provide routine patient care, the OSHA
website includes language that says dental practices should be open for emergency procedures only. Will
dentists in states that allow treatment of non-emergent patients be at risk of violating OSHA standards?
While there’s no definitive answer to that question, statements from both OSHA and the Centers for Disease Control
and Prevention (CDC) indicate the appropriateness of deferring to state and local assessments of risk evaluation that
have resulted in those locations allowing dental health care workers to return to practice.
According to OSHA’s guidance from May 2020:
“Employers should remain alert of changing outbreak conditions, including as they relate to community
spread of the virus and testing availability, and implement infection prevention measures accordingly. As
states or regions satisfy the gating criteria to progress through the phases of the guidelines for Opening
up America Again, employers will likely be able to adapt this guidance to better suit evolving risk levels
and necessary control measures in their workplaces.”
While the CDC does not have regulatory authority over dental practice operations, the agency’s Dental Settings
information, which was published in an April 27 non-binding recommendation, advises that dental health care
providers (DHCP) should regularly consult their state dental boards or other regulating agencies for requirements
specific to their jurisdictions, as information is changing rapidly.
(From the ADA)
Life Member of American Dental Association, Emeritus Fellow of Academy of General Dentistry, American Association of Implant Dentists