Georgia dental sterilization rules: what to test, record and keep

The eight questions at a glance

On a small phone the table is wider than the screen. It scrolls sideways, and every source is named in the third column.

How often to spore test

Georgia’s rules set no spore-test interval (Georgia Board of Dentistry rules, Department 150). What reaches your office instead is CDC guidance, because the board’s unprofessional-conduct rule names “failing to conform to current recommendations of the Centers for Disease Control and Prevention (C.D.C.) for preventing transmission of bloodborne pathogens, and all other communicable diseases to patients”, and says these recommendations “are considered by the Board to be minimum standards of acceptable and prevailing dental practice” (Georgia Board of Dentistry rule 150-8-.01(a)).

In those CDC recommendations, each sterilizer is monitored at least weekly by using a biological indicator with a matching control, that is, a biological indicator and control from the same lot number (CDC, 2003 dental infection-control guidelines). CDC’s summary for dental settings puts it as: a spore test should be used at least weekly to monitor sterilizers (CDC, Summary of Infection Prevention Practices in Dental Settings, 2016).

A sterilizer that runs only now and then gets no separate treatment: CDC does not provide a separate recommendation for sterilizers that are used on a part-time basis (CDC, sterilization monitoring page, 2024).

A biological indicator, or spore test, is a vial of highly resistant bacterial spores run through the sterilizer to prove the cycle killed them.

Implant loads

Georgia’s rules do not mention implant loads (Georgia Board of Dentistry rules, Department 150). Through the board’s rule adopting CDC’s current recommendations as minimum standards (Georgia Board of Dentistry rule 150-8-.01(a)), the guidance is to use a biological indicator for every sterilizer load that contains an implantable device, and to verify results before using the implantable device, whenever possible (CDC, 2003 dental infection-control guidelines).

In the same guideline the items are quarantined until BI results are known, and it adds that in an emergency, placing implantable items in quarantine until spore tests are known to be negative might be impossible (CDC, 2003 dental infection-control guidelines). CDC’s 2024 page words the holding rule as: ideally, implantable items should not be used until they test negative (CDC, sterilization monitoring page, 2024).

Per-cycle checks

Georgia’s rules say nothing about per-cycle checks; the board’s rule reaches them through CDC’s current recommendations instead (Georgia Board of Dentistry rule 150-8-.01(a)). In those recommendations, each load is monitored with mechanical (e.g., time, temperature, and pressure) and chemical indicators (CDC, 2003 dental infection-control guidelines).

A chemical indicator is placed on the inside of each package, and if the internal indicator is not visible from the outside, an exterior chemical indicator is placed on the package as well (CDC, 2003 dental infection-control guidelines). Instrument packs are not used if mechanical or chemical indicators indicate inadequate processing (CDC, 2003 dental infection-control guidelines).

Unwrapped cycles follow the same rule: mechanical and chemical indicators are used for each unwrapped sterilization cycle, and implantable devices are not sterilized unwrapped (CDC, 2003 dental infection-control guidelines).

Air-removal tests

Georgia’s rules are silent on air-removal testing (Georgia Board of Dentistry rules, Department 150). The air-removal test is for pre-vacuum (dynamic-air-removal) steam sterilizers only (CDC/HICPAC, guideline for disinfection and sterilization in healthcare facilities, 2008).

The two CDC texts disagree on how often. The 2003 dental guideline says pre-vacuum sterilizers should be tested periodically for adequate air removal, as recommended by the manufacturer, and that a sterilizer failing the test should not be used until it is inspected by sterilizer maintenance personnel and it passes the test (CDC, 2003 dental infection-control guidelines). The 2008 guideline says an air-removal test (Bowie-Dick test) must be performed daily in an empty dynamic-air-removal sterilizer (CDC/HICPAC, guideline for disinfection and sterilization in healthcare facilities, 2008). This page does not choose between them.

The air-removal test checks that a pre-vacuum steam sterilizer has actually pulled the air out of the chamber before the cycle begins.

After a failed test

Georgia’s rules set no failure procedure; again the board’s rule points to CDC’s current recommendations (Georgia Board of Dentistry rule 150-8-.01(a)). When a spore test comes back positive, those recommendations say to remove the sterilizer from service and review sterilization procedures (e.g., work practices and use of mechanical and chemical indicators) to determine whether operator error could be responsible (CDC, 2003 dental infection-control guidelines).

The spore test is repeated immediately after correctly loading the sterilizer and using the same cycle that produced the failure, and all records of chemical and mechanical monitoring since the last negative BI test are reviewed (CDC, 2003 dental infection-control guidelines). If the repeat spore test is negative, and mechanical and chemical indicators are within normal limits, the sterilizer goes back in service (CDC, 2003 dental infection-control guidelines).

If the repeat is positive, the sterilizer is not used until it has been inspected or repaired or the exact reason for the positive test has been determined (CDC, 2003 dental infection-control guidelines), and items processed since the last negative spore test are recalled, to the extent possible, and reprocessed (CDC, 2003 dental infection-control guidelines).

The CDC texts also disagree on the runs that qualify the unit again. The 2003 guideline says to rechallenge the sterilizer with biological indicator tests in three consecutive empty chamber sterilization cycles after the cause of the sterilizer failure has been determined and corrected (CDC, 2003 dental infection-control guidelines). CDC’s 2024 page says re-challenge with spore tests in three consecutive fully loaded chamber sterilization cycles (CDC, sterilization monitoring page, 2024). This page does not pick a side; Dental Logbook will record the chamber state used in each requalification run.

For a sterilizer that is not steam, one positive biological indicator means treating as nonsterile all items that have been processed in that sterilizer, dating from the cycle with the last negative biological indicator to the next cycle showing satisfactory results (CDC/HICPAC, guideline for disinfection and sterilization in healthcare facilities, 2008).

Notification is left to judgement: CDC’s checklist says identification of such lapses may warrant immediate consultation with the state or local health department and appropriate notification and testing of potentially affected patients (CDC, Infection Prevention Checklist for Dental Settings).

What a log entry holds

Georgia’s rules list no fields for a sterilization record (Georgia Board of Dentistry rules, Department 150). The board’s infection-control committee considered one — type of sterilizer and cycle used; the load identification number; the load contents; the exposure parameters (e.g., time and temperature); the operator’s name; and the results of mechanical, chemical, and biological monitoring — and dropped it from the draft rule as onerous, with the minutes recording that the language “comes directly from the CDC guidelines” (Georgia Board of Dentistry Infection Control Committee minutes, March 31, 2023).

So the field list in use is CDC’s, not a Georgia requirement: for each sterilization cycle, record the type of sterilizer and cycle used; the load identification number; the load contents; the exposure parameters (e.g., time and temperature); the operator’s name or initials; and the results of mechanical, chemical, and biological monitoring (CDC/HICPAC, guideline for disinfection and sterilization in healthcare facilities, 2008).

The packaging carries part of the record: packages should be labeled to show the sterilizer used, the cycle or load number, the date of sterilization and, if applicable, the expiration date (CDC, Summary of Infection Prevention Practices in Dental Settings, 2016).

Dental Logbook will keep that field list on every load record, and it keeps patient names out of sterilizer records.

How long to keep records

Here Georgia’s own rules do give a number: sterilization records must be maintained for a period of not less than three (3) years (Georgia Board of Dentistry rule 150-8-.01(h)5). The rules do not say what form those records must take (Georgia Board of Dentistry rules, Department 150).

Do not confuse this with patient records. A dentist must maintain a patient’s complete treatment record for no less than ten (10) years from the date of the patient’s last office visit, which is a separate patient-record rule and does not cover sterilizer records (Georgia Board of Dentistry rule 150-8-.01(h)4).

CDC’s dental guideline defers to the states on retention: results of biological monitoring should be recorded and sterilization monitoring records retained long enough to comply with state and local regulations (CDC, 2003 dental infection-control guidelines). The 2008 guideline asks for a time period that complies with standards (e.g., 3 years), statutes of limitations, and state and federal regulations (CDC/HICPAC, guideline for disinfection and sterilization in healthcare facilities, 2008).

Dental Logbook will keep every sterilizer record for the life of your account, never delete one automatically, and export your records on request.

Who inspects

In Georgia, enforcement runs through board investigations: the board must promptly conduct investigations to determine whether violations of the rules and laws governing the practice of dentistry or dental hygiene have occurred (Georgia Board of Dentistry rule 150-4-.01(1)). Disciplinary proceedings may be initiated by the Board upon its own motion or upon receipt of a written complaint (Georgia Board of Dentistry rule 150-4-.01(1)).

How often that happens in infection control is on the record too: the board office receives an average of 5 to 15 complaints concerning infection control a year (Georgia Board of Dentistry Infection Control Committee minutes, March 31, 2023).

Nothing in the Georgia rules read here sets a routine inspection of sterilizer records (Georgia Board of Dentistry rules, Department 150). On the practice side, CDC’s checklist treats the assessment as an in-house job: assessment of compliance should be conducted by direct observation of dental personnel during the performance of their duties (CDC, Infection Prevention Checklist for Dental Settings).