From the Summer 2025 Journal of the Colorado Dental Association
By Kim Laudenslager, R.D.H., MPA, CDIPC and Alyssa Aberle, R.D.H., MBA, CDIPC
In addition to being OSHA and infection control trainers, we are 
often asked to serve as contract inspectors for the Colorado Dental Board when complaints warrant investigation. The CDA recently asked what the most common violations were in our investigations.
While not a violation, the number one cause of violations is undoubtedly “lack of organization.” OSHA requires that all dental offices assign one person to be in charge of compliance (usually referred to as the OSHA Compliance Coordinator) and it is that person’s responsibility to delegate and oversee duties and responsibilities assigned to other employees. The OSHA Compliance Coordinator’s job is critical, and delegation of duties is the norm, but dentists and hygienists should make it a point to “trust but periodically verify” the office is in 100% compliance.
Top 5 Most Common Violations:
- Training
Improper training has been cited in every OSHA and dental board inspection that we have seen. As a reminder, annual training must be:
- Conducted annually for all team members
- Conducted in a live and interactive format with a qualified trainer
- Properly documented
- Spore Testing / Biological Monitoring
Failure to conduct weekly spore testing is the number one reason dental boards temporarily shut down (summarily suspend) dental offices. “At least weekly spore testing,” as required since 1993, is one of the most important things we do as dental professionals to verify sterilization parameters are met and ensure patient safety. As a reminder, weekly spore testing must:
- Be conducted on EVERY sterilizer EVERY week
- Have written protocol to follow in the event of a failed spore test
- Be properly documented
- Sterilization Processing and Packaging of Instruments
As with spore testing, proper sterilization of instruments is critical for patient safety. The following are errors cited as violations:
- Improper layout and understanding of clean to dirty workflow
- Improper sterilizer loading and/or overloading
- Improper instrument packaging technique
- Operatory Turnaround and Cross-Contamination
Since the pandemic, patients are more aware than ever about disease transmission and cross-contamination. When patients visit multiple dental offices (ex: general dentist, orthodontist, pediatric dentist, endodontist, etc.), which is common these days, they compare what they see in one office with what they see in another office. This has driven and caused higher rates of patient complaints and concerns. The following are errors cited as violations:
- Lack of barriers on required clinical contact surfaces
- Lack of understanding regarding disinfectant Tuberculocidal kill time resulting in improper turnaround technique
- Improper disinfectant used and/or mixed and matched products
- Waterline Testing
Dental Unit Waterline (DUWL) contamination cases in California and Georgia have made national news the past few years and the Centers for Disease Control and Prevention has issued numerous alerts regarding DUWL contamination. If you are unfamiliar with these cases, please educate yourself by conducting an internet search. Given these stories, dental boards are appropriately taking compliance with waterline testing requirements very seriously.
- Follow the DUWL manufacturer’s instructions for use (IFU) to properly treat, shock and test DUWLs.
- Note: All current DUWL manufacturers require conducting “at least quarterly” testing of DUWLs to ensure the water quality requirement of <500 CFU/mL is met (meaning less than 500 individual bacteria can grow within the waterline).
- Properly document DUWL testing results.
Compliance is a team effort, but it is the dentists and hygienists who will be disciplined if something falls through the cracks. These violations are all preventable with proper training, communication and enforcement.
