Occupational Safety and Health Administration (OSHA)

Key Points

  • Employers have responsibilities for the occupational safety of their employees.
  • The Occupational Safety and Health Administration (OSHA) is the U.S. governmental agency that has the mission to assure the safety and health of America's workers.
  • OSHA sets and enforces standards that address potential workplace hazards; provides training, outreach, and education; establishes partnerships; and encourages continual improvement in workplace safety and health.  
  • For dentistry, infectious disease and hazardous chemicals are examples of potential workplace hazards of concern; the following sections will address certain OSHA standards specific to dental offices.
  • When there is no standard, OSHA’s “General Duty Clause” may be used to provide regulatory guidance and enforcement for occupational exposures.
Introduction
Employers have responsibilities for the occupational safety of their employees.  The Occupational Safety and Health Administration (OSHA) is the U.S. governmental agency within the Department of Labor that has the mission to assure the safety and health of America's workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health.  OSHA accomplishes this task by creating standards that address potential workplace hazards.  The Agency was established as part of the 1970 Occupational Safety and Health (OSH) Act.1  For dentistry, infectious disease and hazardous chemicals are examples of potential workplace hazards of concern; the following sections will address certain OSHA standards specific to dental offices. When there is no standard, the Agency may use OSHA’s “General Duty Clause” to guide regulatory enforcement for occupational exposures.

Training of employees occurs when the employee begins the job, and at least yearly thereafter.  Employers should provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure. The additional training may be limited to addressing the new exposures created.2  Engaging with the OSHA online resources (see Additional Resources section below) can improve knowledge of OSHA requirements and familiarity with standards facilitates compliance.

Regulatory Issues
OSHA’s requirements are federal regulations and are found in Title 29 of the Code of Federal Regulations (29 CFR 1910).  Thus, they are enforced by law, as opposed to guidelines and recommendations set forth by agencies and organizations like the Centers for Disease Control and Prevention (CDC) and the ADA.  OSHA standards related to dentistry are available, and interpretations and directives of enforcement are available.  The ADA’s Dental Practice Resources have developed resources to provide members with insight about implementing the OSHA requirement (login required).

While federal regulations such as OSHA provide a base level of regulations for compliance, local and state regulating authorities and agencies may have additional or specific requirements that exceed federal OSHA standards.  For example, a state dental board may require compliance with the CDC’s Infection Control Guidelines for Dental Healthcare Settings.3 Furthermore, consideration of additional guidelines from other regulatory bodies, e.g., the CDC, may be prudent.

The following sections address many of the OSHA compliance issues that a dental practitioner might face, as well as other issues that may not be covered by OSHA, but that may be regulated by state or local laws or fall under other federal agency guidelines and recommendations. 

Bloodborne Pathogens Standard
The OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030)2 is designed to protect workers exposed to blood or other potentially infectious materials (e.g., saliva in dental procedures), and covers training, hepatitis B virus vaccination, personal protective equipment, engineering and work practice controls, housekeeping, and regulated waste.  OSHA has a “quick reference guide” for the Bloodborne Pathogens Standard. For further assistance, the ADA has developed an OSHA Bloodborne Pathogens Standard checklist for ADA members (login required)


Personal Protective Equipment
Personal protective equipment (PPE, including gloves, gowns, masks, and eye protection) must be provided by the employer as well as cleaned and maintained to provide functional and protective efficacy, according to 29 CFR 1910.132.4 It is the responsibility of the employer to assess risk from hazards and to make appropriate PPE available. Employees may use their own PPE, but the employer is responsible for its maintenance and cleaning. Further information from OSHA is available on their PPE Safety and Health Topics page. Frequently asked questions regarding PPE use in dentistry are posted on OSHA’s website in a Standards Interpretation letter.5 The bloodborne pathogens standard also addresses PPE, at section 1910.1030(d)(3) of the CFR.2

Hazard Assessment and PPE

As part of the Personal Protective Equipment (PPE) regulation, OSHA has established a subsection describing the PPE hazard assessment process for determining potential workplace hazards and implementing control measures.  According to Subsection 1910.132(d), Hazard assessment and equipment selection, the employer must assess the hazards that may demand the use of certain categories of PPE, and further (1) make available the appropriate PPE for each hazard type, (2) communicate these PPE requirements to staff, and (3) ensure proper fit.  Finally, the employer must verify the hazard assessment in a written document, including information regarding the workplace assessed, the person verifying the assessment, and the date the hazard assessment occurred. Nonmandatory compliance guidelines on conducting the assessment and implementing requirements can be found in Appendix B to Subpart 1.  For dentistry, examples of workplaces hazards include not only the risk of airborne and bloodborne pathogens, but also chemical, eye and noise hazards.

Requirements pertaining to respiratory protection PPE such as N95 masks are found in Subsection 1910.134, Respiratory Protection. In a workplace where respirators are necessary to protect the health of the employee, or whenever respirators are required by the employer, the employer must develop and implement a written respiratory protection program with required worksite-specific procedures and elements. More information about OSHA’s respiratory protection standards are available in the OSHA publications Respiratory Protection and Small Entity Compliance Guide for the Respiratory Protection Standard.

General information about identifying and assessing hazards in the workplace is available in an OSHA resource entitled Recommended Practices for Safety and Health Programs: Hazard identification and Assessment for the general workplace, which describes six steps in detail:

  1. Collect existing information about workplace hazards
  2. Inspect the workplace for safety hazards
  3. Identify health hazards
  4. Conduct incident investigations
  5. Identify hazards associated with emergency and nonroutine situations
  6. Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control
 
Exposure Control Plan
A component of OSHA compliance is a written exposure control plan, which applies to both bloodborne pathogens and hazardous chemicals (in 29 CFR 1910.1020).6  The OSHA publication, Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards (2003), contains sample exposure control plans for both.7

Staff Immunization Requirements
Employers are responsible for offering the hepatitis B virus vaccination to employees within the first ten days of an employee beginning their position.  Employers are also required to cover the cost of the vaccinations.2  Employees may refuse vaccination, and OSHA provides a declination form for this purpose.  An employee who has refused the vaccination may opt to receive it at a future date.  No booster is currently recommended for persons with normal immune status who have been fully vaccinated.8 Although studies are ongoing to assess whether booster doses of HBV vaccine will be needed in the future,9 recently published data from a 30-year cohort follow-up suggests that booster doses may not needed.10

Other vaccinations for health-care personnel that are not regulated by OSHA, but may be required under state law, include the seasonal influenza vaccine; other strongly recommended vaccinations can be found on CDC.gov.  For additional information on immunizations, visit the Staff Immunization section of the ADA’s Managing the Regulatory Environment resource (login required).

Needle Safety
Needle safety may be approached through both work practice controls—such as prohibition of two-handed needle recapping, and engineering controls such as sharps containers, masks, gloves, and devices for one-handed needle capping.  “If recapping must be performed, it must be accomplished by means of a recapping device which adequately protects the hands or a properly performed one hand scoop technique.”11 Engineered needle safety products are also ways to help reduce and eliminate percutaneous exposure. Needleless systems, if available, are recommended.  Resources on “Safer Needle Devices” may be found on the Bloodborne Pathogens Standard page on evaluation and controls.12

Sharps Containers
Requirements for sharps containers can be found in section 1910.1030(d)(2) of the Bloodborne Pathogens Standard.2  Containers for contaminated sharps must be closable, puncture resistant, leakproof on the sides and bottom, appropriately marked or color-coded, and kept upright during use.2  Mounting the container unit is a method of keeping it upright, but it is not mandatory.13

Please note that OSHA does not specify where sharps containers are to be located in a dental office.  OSHA has indicated that the employer is to determine placement based on location accessibility and reasonable proximity to the area where sharps are used.  According to the answer to Question 39 in OSHA’s Frequently Asked Questions Concerning the Bloodborne Pathogens Standard, “Sharps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used (e.g., patient care areas) or can be reasonably anticipated to be found (e.g., laundries).”14

Percutaneous Exposures/Sharps Injuries
In the event of an exposure incident (e.g., needlestick, sharps injury), employers are required to make available to the exposed employee a confidential medical evaluation and follow-up that includes: documentation of the exposure; identification of the source individual; testing of the source individual’s blood for infectivity status (i.e., HBV, HIV); collection of the blood and testing; post-exposure prophylaxis, if indicated; counseling; and a healthcare professional’s written opinion, among other requirements.  A complete list of requirements of the standard may be found in section 1910.1030(f)(3) of the Bloodborne Pathogen Standard.15 For more information, the American Dental Association and OSHA developed the “Employer Obligations After Exposure Incidents” for dental professionals.16

Laundry
According to “Frequently Asked Questions” regarding the OSHA Bloodborne Pathogens Standard, employers are responsible for laundering gowns and lab jackets.  Dental practices may install washing machines in the office, they may contract with commercial laundry services, and disposable gowns and jackets may also be used.  Scrubs, if worn under PPE, are generally not covered by the laundry requirements of the standard unless the scrubs do become contaminated with blood or other potentially infectious materials.  Employees are not permitted to take contaminated laundry home.17

Environmental Surfaces/Carpet in Dental Offices
OSHA requires disinfection of environmental surfaces with an “appropriate disinfectant.”18 Appropriate disinfectants include a diluted bleach solution and Environmental Protection Agency (EPA) -registered antimicrobial products.19 Fresh solutions of diluted household bleach made up every 24 hours are also considered appropriate for disinfection of environmental surfaces and for decontamination of sites. Contact time for bleach is generally considered to be the time it takes the product to air dry.

OSHA does not require offices to replace carpet in dental operatories, nor does it address the type of flooring in the Bloodborne Pathogen Standard.2  In terms of the cleaning routine (29 CFR 1910.1030(d)(4)(i)), OSHA states the “employer must determine and implement an appropriate written schedule of cleaning and decontamination based upon the location within the facility.”18  The Centers for Disease Control and Prevention (CDC) suggest “replacement with nonporous material when it is time to replace flooring.”20

Nitrous Oxide Analgesia
There are no definitive OSHA regulations on nitrous oxide or anesthetic gases other than 29 CFR 1910.101 which regulates inspections, safety, and handling of compressed gases.21  Nitrous oxide is mentioned in the OSHA guideline, Anesthetic Gases: Guidelines for Workplace Exposures. The guideline is “advisory in nature, informational in content, and […] intended to assist employers in providing a safe and healthful workplace through effective prevention programs adapted to the needs of each place of employment.”22 Information from the National Institute for Occupational Safety and Health (NIOSH) on the safe use and control of nitrous oxide is now available.23 

Recommendations from the ADA for the safe use of nitrous oxide is now available.

Emergency/First Aid Kits
While 29 CFR 1910.151 addresses the first aid kit and first aid training required at all workplaces, it does not include specific guidance about a first aid or emergency kit for a dental or medical office, nor does it provide a list of required contents.  Many states have adopted the ANSI Z308.1 specifications for minimal contents, and it is highly recommended that contents are suited to meet the expected needs of the dental practice.  OSHA provides an appendix to 1910.151, First aid kits (Non-Mandatory), which states “Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.”24 The ADA has published recommendations for emergency drugs and equipment25 as well as preparing staff for medical emergencies.26

Radiography and Workplace Safety
The OSHA Ionizing Radiation Standard (29 CFR 1910.1096) regulates occupational exposure and covers exposure and control.27  This Standard is incorporated in the following recommendations.

The ADA/U.S. Department of Health and Human Services’ Dental Radiographic Examinations: Recommendations for Patient Selection and Limiting Radiation Exposure28 contains a section on “Operator Protection” that addresses occupational safety, including the wearing of dosimeters by pregnant personnel, barrier shielding, and work practice controls such as standing behind the direction of the beam.  Recommendations for hand held x-ray units, including holding the device at mid-torso height, orienting the shielding ring properly with respect to the operator, and keeping the cone as close to the patient’s face as practical.

Additional information on radiation safety for dentistry may be found in Radiation Protection in Dentistry, a publication of the National Council on Radiation Protection and Measurements.29

Hazard Communication
The 1994 version of the OSHA Hazard Communication Standard (29 CFR 1910.1200), designed to protect employees from exposures to chemicals in the performance of their jobs, was modified to conform to the United Nations “Globally Harmonized System of Classification and Labeling of Chemicals.”30 The new OSHA Hazard Communication Standard (effective date May 25, 2012)31 now includes a new “Safety Data Sheet” (SDS; previously known as “Material Safety Data Sheet” or MSDS) format organization, and the use of pictograms to identify chemical hazards.  Compliance with the new format was required beginning June 1, 2016.

Labeling and Pictograms
The 2012 OSHA Hazard Communication Standard31 requires manufacturers to label their products in accord with the new requirements, including pictograms of chemical hazards (e.g., corrosives, gases under pressure, flammables, explosives).  Employers are responsible for making sure that products they use are properly labeled.  For products that are transferred to smaller containers, employers are allowed to create their own labels, as long as they communicate the hazard information specific to the chemicals.32, 33 Examples of pictograms follow:
Pictogram of acute toxicity: a skull and crossbones within a red box Pictogram for corrosives, two beakers pouring a burning liquid on a hand and surface within a red box
Acute Toxicity
Corrosives

Safety Data Sheets—Electronic Storage and Access
According to the 2014 OSHA publication, Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals,32 (pp. 20-21) employers must maintain copies of safety data sheets in their workplaces, and must ensure that safety data sheets are readily accessible.  Compliance with the accessibility requirement may be accomplished in a variety of different ways, including in a binder or electronically.  If electronic, a back-up system must be in place to provide ready accessibility. “Any approach may be used,” if it provides the information when needed.32 A record of each hazardous chemical must be maintained for 30 years.6, 34  Record-keeping standards6 may be found in Section 1910.1020(d)(1)(ii)(B), and a description of alternative record-keeping in a Standard Interpretations letter.35

Eye Protection and Eyewash Stations

Eye and face protection is covered under 29 CFR 1910.133, and OSHA provides an e-tool to assist in selecting appropriate protection according to hazard.  It is the responsibility of the employer to assess risk from hazards such as “liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation”36 and to ensure that proper eye protection is utilized.

As noted in the previous section, safety data sheets that accompany products used in dental offices identify which products are corrosive and/or caustic. The OSHA standard for Medical and First Aid (29 CFR 1910.151), contains a requirement that employers provide “suitable facilities for quick drenching or flushing of the eyes and body” in situations where employees may be exposed to corrosive materials.37

In a Standard Interpretations letter,38 OSHA has acknowledged that the Standard does not require employers to have an emergency eyewash if none of the materials used in the work area is an injurious corrosive chemical; however, the letter also states:

“…while not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI Z358.1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of ’hazardous material’ would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans.”

In the event of an inspection of a dental office where corrosive materials are in use, a workplace without an eyewash station (i.e., “suitable facilities”), could be cited by OSHA under 29 CFR 1910.151(c).  Information about eyewash stations is available from the Organization for Safety, Asepsis, and Prevention (OSAP).39

For dental offices with state occupational safety plans, consult your area administrator for applicable requirements.

Sterilization of Equipment
OSHA does not regulate sterilization of dental equipment, but state and local regulating authorities or dental boards may require compliance with CDC infection control standards.  The ADA provides a number of resources in the Oral Health Topics pages for Infection Control and Dental Unit Waterlines, as well as in the ADA Center for Professional Success Managing the Regulatory Environment (login required).

Waste Management
Although the Bloodborne Pathogens Standard discussed above addresses exposure to medical waste, disposal of medical and hazardous waste is generally a state and local regulatory issue.  More information may be found in the Medical Waste Disposal section of the ADA resource Managing the Regulatory Environment (login required)

General Duty Clause
The Occupational Safety and Health Act of 1970, Section 5, Duties,40 states:
“(a) Each employer – (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.”
In the absence of specific standards, this General Duty clause covers occupational safety in dental offices, including ergonomics, nitrous oxide, and workplace violence, and other occupational safety and health exposures.

ADA Policy on Occupational Safety and Health
POLICIES AND RECOMMENDATIONS ON OCCUPATIONAL SAFETY AND HEALTH
(Trans.2016:322)

Resolved, that the ADA recognizes the importance of engineering and work practice controls recommended by the Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control and Prevention in preventing the transmission of bloodborne pathogens from needlestick and other sharps-related injuries in dental settings, and be it further

Resolved, that the ADA encourages dentists to maintain knowledge of and compliance with federal standards and other applicable regulations for eliminating or minimizing occupational exposure to bloodborne pathogens and preventing injury and illness in dental settings, and be it further

Resolved, that it is the position of the American Dental Association that its members, in an effort to promote a safe workplace, use materials in the dental health care setting that have been appropriately labeled by the manufacturer or distributor to comply with the OSHA Hazard Communication Standard, and for which the manufacturer/distributor has supplied a current safety data sheet (SDS), and be it further

Resolved, that the ADA support its members by providing access to current information, forms, and prototypes as needed to help them comply with occupational safety and health requirements affecting dental health care settings, and be it further

Resolved, that the ADA encourages and supports fair systems of compliance with applicable state and federal law(s) for preventing injury and illness in the dental office.


American Dental Association
Adopted 2016

References
  1. Occupational Safety & Health Administration. OSH Act of 1970. U.S. Department of Labor. Accessed January 22, 2016.
  2. Occupational Safety & Health Administration. Bloodborne Pathogens Standard. 1910.1030: U.S. Department of Labor; 2012.
  3. Centers for Disease Control and Prevention. Summary of Infection Prevention Practices in Dental Settings: Basic Expectations for Safe Care. Atlanta, GA: National Center for Chronic Disease Prevention and Health Promotion, Division of Oral Health; 2016.
  4. Occupational Safety & Health Administration. General Requirements: Personal Protective Equipment. 1920.132: U.S. Department of Labor; 2016.
  5. Occupational Safety & Health Administration. Standard Interpretations Letter: Richard E. Fairfax, Director, Directorate of Enforcement Programs to Mr. Joseph Kaye, JK Solutions, Inc.: U.S. Department of Labor 2009. Accessed December 5, 2017.
  6. Occupational Safety & Health Administration. Access to employee exposure and medical records: Toxic and Hazardous Substances. 1910.1020: U.S. Department of Labor; 2011.
  7. Occupational Safety & Health Administration. Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards. U.S. Department of Labor. Accessed January 22, 2016.
  8. Division of Viral Hepatitis and National Center for HIV/AIDS Viral Hepatitis STD and TB Prevention. Hepatitis B FAQs for the Public. Centers for Disease Control and Prevention (CDC). 2015.  Accessed January 22, 2016.
  9. Immunization Action Coalition. Ask the Experts: Diseases & Vaccines: Hepatitis B.  2015. Accessed January 22, 2016.
  10. Bruce MG, Bruden D, Hurlburt D, et al. Antibody Levels and Protection After Hepatitis B Vaccine: Results of a 30-Year Follow-up Study and Response to a Booster Dose. J Infect Dis 2016.
  11. Occupational Safety & Health Administration. Standard Interpretations Letter: Roger A. Clark, Director to Douglas A. Witte, DDS, Tyler, Texas.: U.S. Department of Labor 1992.  Accessed January 31, 2018.
  12. Occupational Safety & Health Administration. Bloodborne Pathogens and Needlestick Prevention: Evaluation and Controls. U.S. Department of Labor.  Accessed January 22, 2016.
  13. Occupational Safety & Health Administration. Standard Interpretations Letter: Richard E. Fairfax, Director Directorate of Enforcement Programs to Ms. Patte Shambaugh, Pinnacle Health System Laboratory (April 18,2008). U.S. Department of Labor 2008.  Accessed December 5, 2017.
  14. Occupational Safety & Health Administration. Most Frequently Asked Questions Concerning the Bloodborne Pathogens Standard (1910.1030): Question 39 (corrected 11/01/11). U.S. Department of Labor. Accessed January 22, 2016.
  15. Occupational Safety & Health Administration. Bloodborne Pathogens Standard: Section 1910.1030(f)(3) Post-exposure Evaluation and Follow-up. U.S. Department of Labor.  Accessed January 22, 2016.
  16. American Dental Association and Occupational Safety & Health Administration. Employer Obligations After Exposure Incidents OSHA. American Dental Association. Accessed January 22, 2016.
  17. Occupational Safety & Health Administration. Most Frequently Asked Questions Concerning the Bloodborne Pathogens Standard (1910.1030): Questions 43, 44, 45, 46, 47 (corrected 11/01/2011). U.S. Department of Labor. Accessed January 22, 2016.
  18. Occupational Safety & Health Administration. Housekeeping. U.S. Department of Labor. Accessed January 29 2016.
  19. U.S. Environmental Protection Agency. Selected EPA-registered Disinfectants. Accessed January 29, 2016.
  20. 2003 CDC infection control recommendations for dental health-care settings. Compend Contin Educ Dent 2004;25(1 Suppl):43-8, 50-3.
  21. Occupational Safety & Health Administration. Compressed Gases (general requirements). 1910.101: U.S. Department of Labor; 1996.
  22. OSHA Directorate of Technical Support and Emergency Management. Anesthetic Gases: Guidelines for Workplace Exposures. U.S. Department of Labor 1999. Accessed January 22, 2016.
  23. National Institute of Occupational Safety and Health (NIOSH) Education and Information Division. Workplace Safety & Health Topics:  Nitrous Oxide NIOSH Resources. Centers for Disease Control and Prevention (CDC) 2012. Accessed January 22, 2016.
  24. Occupational Safety & Health Administration. Appendix A to § 1910.151 -- First aid kits (Non-Mandatory). 1910.151: U.S. Department of Labor; 2011.
  25. Rosenberg M. Preparing for medical emergencies: the essential drugs and equipment for the dental office. J Am Dent Assoc 2010;141 Suppl 1:14S-9S.
  26. Haas DA. Preparing dental office staff members for emergencies: developing a basic action plan. J Am Dent Assoc 2010;141 Suppl 1:8S-13S.
  27. Occupational Safety & Health Administration. Ionizing Radiation: Toxic and Hazardous Substances. 1910.1096: U.S. Department of Labor; 1996.
  28. American Dental Association and U.S. Department of Health and Human Services. Dental Radiographic Examinations: Recommendations for Patient Selection and Limiting Radiation Exposure (Rev. 2012). Accessed January 26, 2016.
  29. National Council on Radiation Protection Measurements. Radiation protection in dentistry: Recommendations of the National Council on Radiation Protection and Measurements. Bethesda, MD: National Council on Radiation Protection and Measurements; 2003.
  30. Occupational Safety & Health Administration. Hazard Communication: Toxic and Hazardous Substances. 1910.1200: U.S. Department of Labor; 2012.
  31. Occupational Safety & Health Administration. Hazard Communication Standard. U.S. Department of Labor. Accessed January 26, 2016.
  32. Occupational Safety & Health Administration. Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals(OSHA). U.S. Department of Labor. Accessed December 6 2017.
  33. Occupational Safety & Health Administration. OSHA Brief: Hazard Communication Standard: Labels and Pictograms: U.S. Department of Labor; 2013.
  34. Occupational Safety & Health Administration. Standard Interpretations Letter: John A. Pendergrass, Assistant Secretary to Mr. Dudley Robinson, Director of Government Affairs, Printing Industry of Illinois-Indiana Association. U.S. Department of Labor 1987. Accessed December 6 2017.
  35. Occupational Safety & Health Administration. Standard Interpretations Letter: Retention of Exposure Records Under 29 CFR 1910.1020. U.S. Department of Labor 1985. Accessed December 6 2017.
  36. Occupational Safety & Health Administration. Eye and Face Protection. 1910.133; 2016.
  37. Occupational Safety & Health Administration. Medical and First Aid 1910.151: U.S. Department of Labor; 1998.
  38. Occupational Safety & Health Administration. Standard Interpretations Letter: Robert E. Fairfax, Director of Enforcement, to Mr. Donald Bossow, Johnson Diversey, Inc. (June 1, 2009). U.S. Department of Labor. Accessed March 31 2016.
  39. Organization for Safety Asepsis and Prevention (OSAP) Eyewash stations with faucets that turn upward, can they be considered an eyewash station? Accessed March 31, 2016.
  40. Occupational Safety & Health Administration. OSH Act of 1970: Section 5, Duties. U.S. Department of Labor. Accessed January 26, 2016.

ADA Resources
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ADA Catalog:
  • The ADA Practical Guide to Effective Infection Control Workbook and DVD (Item #P692)
  • The ADA Practical Guide to OSHA Compliance Manual and CD-ROM with Update Service (Item #S696B)
  • The ADA Practical Guide to OSHA Training: Compliance for Dental Professionals Workbook and DVD (Item #889)
  • If Saliva Were Red Training Manual and DVD (Item #W616)

ADA Oral Health Topics:  Infection Control

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Last Updated: May 11, 2020

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