- Hazard assessments are required under OSHA. Dental practices must have a safety plan for exposure control and COVID-19. Repeat the hazard assessment along with the checklist regularly as COVID-19 conditions change.
- Each dentist should stay abreast of guidance from federal, state, local, tribal, and/or territorial health agencies, and consider how to incorporate those recommendations and resources into workplace-specific plans.
- Best practices for assessing and managing the hazards in a workplace should take an integrative approach, incorporating the evidence-based scientific data in conjunction with psychosocial, state and community factors.
- Each dentist will need to use their best professional judgment when making decisions.
- Patient pre-appointment screenings are still necessary.
- Everyone (patients, non-employees on site, and staff) must be screened prior to entry and those with suspected or confirmed COVID-19 are not permitted to enter.
Pre-Appointment Screening ProcessOn June 10, 2021, the Occupational Safety and Health Administration (OSHA) issued an Emergency Temporary Standard (ETS) for COVID-19 in healthcare settings. For a complete list of resources, please see OSHA Emergency Temporary Standard. You may also reference the fact sheet. Most dental offices are exempt from this standard because they fall under the exclusion for “non-hospital ambulatory care settings where all non-employees are screened prior to entry and people with suspected or confirmed COVID-19 are not permitted to enter those settings;”
- In order to fall under this exemption, dental offices must continue to screen all who enter the practice in order to ensure people with suspected or confirmed COVID-19 are being kept out.
Although there are many different symptoms associated with COVID-19, there may not be a need to treat every patient with a single non-specific symptom (e.g., a headache) as a suspected case of COVID-19 and reschedule their treatment. Consider focusing the screening questions on “new” or “unexpected” symptoms (e.g., a chronic cough would not be a positive screen). Consider including these symptoms:
- Fever or feeling feverish (chills, sweating)
- New cough
- Difficulty breathing
- Sore throat
- Muscle aches or body aches
- Vomiting or diarrhea
- New loss of taste or smell. For a sample screening document, see the CDC COVID-19 Facility Access Tool.
- The ADA Hazard Assessment and the corresponding checklist should be reviewed as needed as COVID-19 outbreak conditions change, including new information about the virus, its transmission, and impacts, becomes available.
- Once an assessment is complete, the information and insights gathered should help supplement the office’s existing OSHA safety plans for exposure control. Every practice owner needs to think about the hazards and control measures necessary to keep workers safe and healthy. Control measures will be unique to each business and the particular conditions of the region. For a risk assessment to be effective the dentist and staff must:
- Take action to implement reasonable control measures to reduce or remove risks when possible.
- Review the risk assessment and the resulting plan on a regular basis.
- Consider the ease of implementation, the effectiveness of the action, and the cost of each mitigation strategy.
- Hazard assessment, risk mitigation strategies, and the office safety plan for infection control should be well documented to include the reasons for a decision.
- Provide employees with up to date education and training.
- Inform staff as to the location of the written plan (e.g. the file folder, the computer document, the binder).
In-Office Patient Registration Procedures
- Mask use should reflect federal, state, and local regulations and conditions.
- Screen patients as appropriate.
- Reschedule known or suspected COVID-19 positive patients or provide a referral to an appropriately equipped facility.
- Continue routine sanitization and disinfection of high touch areas in the patient registration area.
Reception Area Preparation Strategies
- Mask usage as per federal, state, and local regulations and conditions.
- Social distancing as per federal, state, and local regulations.
- Continue routine sanitization and disinfection of high touch areas in the patient registration area. Resource: CDC’s Steps Healthcare Facilities Can Take to Stay Prepared for COVID-19
- Refer to the hazard assessment when establishing clinic protocols.
- Use best clinical judgment regarding hand shaking.
Staff Protection Strategies
Professional judgment should be exercised when considering the following strategies. Pay attention to any evolving CDC guidelines for health care providers, as well as state and local ordinances. Be sure to check state regulations for vaccine mandates.
- Source control. In general, fully vaccinated Dental Health Care Personnel (DHCP) should continue to wear source control while at work in most instances. However, fully vaccinated DHCP could dine and socialize together in break rooms and conduct in-person meetings without source control or physical distancing. If unvaccinated DHCP are present, everyone should wear source control and adjust furniture to maintain social distancing of 6 feet between employees, where possible.
- Staff who use public transportation. The CDC issued an Order that required face masks to be worn by all people while on public transportation (which included all passengers and all personnel operating conveyances) traveling into, within, or out of the United States and U.S. territories. While those who are fully vaccinated may resume many activities without wearing a mask, the travel environment presents a unique set of circumstances based on the number and close interaction of travelers (both vaccinated and unvaccinated).
- Utilize the Hazard Assessment and the Checklist.
Take steps to ensure that everyone adheres to hand hygiene practices; upon entry into the workplace; before and after any contact with patients; after contact with contaminated surfaces or equipment; and upon entry to and exit from common private staff areas such as employee lounges, locker rooms, or lunch rooms. See the ADA’s Hand Hygiene for the Dental Team resource.
COVID-19 Employee Screening
Dentists should continue to screen staff and other non-patients entering the practice so that suspected or known COVID-19 positive people are not entering the facility. Screening may be conducted by asking employees to self-monitor before reporting to work or may be conducted in-person by the employer.