Guide · Dental offices in the United States
OSHA bloodborne pathogens training records for dental offices
The short answer
Train every employee with occupational exposure at the time of initial assignment to tasks where that exposure may take place, and at least annually thereafter (OSHA bloodborne pathogens standard, 29 CFR 1910.1030). For each session, record the dates, the contents or a summary, the names and qualifications of the persons conducting it, and the names and job titles of everyone who attended, and keep that record for 3 years (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
Who needs training, and when
Training is tied to the tasks, not the job title: it is required at the time of initial assignment to tasks where occupational exposure may take place (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
After that it runs on a yearly clock: at least annually thereafter, and annual training for all employees must be provided within one year of their previous training (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
Dental offices also keep a second schedule in view. CDC's checklist expects the staff who reprocess reusable dental instruments and devices to be trained upon hire, at least annually, and whenever new equipment or processes are introduced (CDC, Infection Prevention Checklist for Dental Settings).
What to record
The standard names four items for the training record (OSHA bloodborne pathogens standard, 29 CFR 1910.1030):
- Dates of the training sessions
- Contents of the training sessions, or a summary
- Names and qualifications of the persons conducting the training
- Names and job titles of all persons attending the training sessions
The second item accepts a summary, so a short outline of what the session covered stands in for the full contents (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
A good log also shows who wrote each entry and when it was written.
How long to keep the records
Training records are maintained for 3 years from the date on which the training occurred (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
CDC's checklist tells dental offices to maintain training records in accordance with state and federal requirements (CDC, Infection Prevention Checklist for Dental Settings). Read that next to the state rules further down this page.
Who can ask for the records
The employer must ensure that all records the standard requires to be maintained are made available upon request to the Assistant Secretary and the Director for examination and copying (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
Keep the records where a colleague can find them and copy them on the day they are asked for.
Where state training rules differ
The federal schedule is not the only one a dental office answers to. Three examples show how far apart the states are, each with its own source:
- New YorkDentists must complete course work or training appropriate to their practice regarding infection control and barrier precautions every four years, and must attest to the State Education Department on their first licensure or registration application and at every subsequent registration (New York Education Law §6505-b; New York State Education Department).
- GeorgiaEffective on and after January 1, 2024, two hours of the minimum continuing education requirement must include education and training regarding infection control in the practice of dentistry, which shall include education and training regarding dental unit water lines (Georgia Board of Dentistry rule 150-3-.09).
- PennsylvaniaThe board's continuing-education rule does not mention infection control or sterilization; its one mandated subject is child abuse recognition and reporting, 2 of the required hours (Pennsylvania Code 49 Pa. Code §33.401).
So the states do not line up: New York runs a four-year cycle, Georgia sets two continuing-education hours, and Pennsylvania's rule is silent on infection control (New York Education Law §6505-b; Georgia Board of Dentistry rule 150-3-.09; Pennsylvania Code 49 Pa. Code §33.401).
What this page does not cover
This page is about training records only. Employee medical records are separate: they are kept confidential, and the employer maintains them for at least the duration of employment plus 30 years (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
This page does not cover exposure follow-up, which can include identification and documentation of the source individual, who is often a patient (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).
The sharps injury log applies to employers who are required to keep a log of occupational injuries and illnesses; offices of dentists are listed as partially exempt, so a dental office does not need to keep OSHA injury and illness records unless the government asks it to keep the records (OSHA bloodborne pathogens standard, 29 CFR 1910.1030; OSHA injury and illness recordkeeping rules, 29 CFR part 1904).
What Dental Logbook will do
Dental Logbook is in development. It will keep one training record per session with the four items above, remind the office before the next annual training is due, and export the records as a file whenever someone asks for them.
It will not store employee medical records, and it will not store anything about patients.