Minimize the risk of exposure to bloodborne pathogens through education and planning


To comply with Cal/OSHA standards, California dental practices are required to train any team member who may be exposed to bloodborne pathogens. CDA has resources to help your practice achieve compliance.

Dental professionals can be exposed to many occupational hazards. The Federal Occupational Safety and Health Administration (OSHA) and the State of California have legal obligations for employers to create and maintain safe workplaces. California dental practices must meet infection control and safety standards, including those that address bloodborne pathogens and biological agents, for federal and state agencies.

OSHA Bloodborne Pathogen Standard applies to all employers whose employees are occupationally exposed to blood or other potentially infectious material, regardless of the number of workers employed.

Dentists’ Insurance Company handles workers’ compensation claims related to a wide range of workplace incidents, but the most common reported injuries are needle stick injuries. These injuries can expose healthcare workers to blood-borne pathogens, including hepatitis B, hepatitis C and HIV.

It’s no surprise, then, that to comply with Cal/OSHA standards, California dental practices are required to train any team member who may be exposed to blood-borne pathogens. What might surprise practice leaders is that this training is required by both the federal government and Cal/OSHA on an annual basis. The confusion exists because many assume that the standards for bloodborne pathogen training are the same as those for infection control training, which must be completed every two years by the Dental Board of California.

When a sharps injury occurs, practice owners are responsible for managing possible exposure to bloodborne pathogens. The dental insurance company’s advice line often receives calls about how to manage risk and mitigate liability.

A common scenario

In one case reported to the TDIC Infoline, a full-time dental assistant had just finished assisting a dentist with a root canal procedure. In a hurry to prepare the operating room for the next patient, the assistant did not notice that the needle was not covered with a cap. Hurrying to collect the instruments, she pricked her right thumb with the needle, then reported the incident to the dentist.

When the dentist called the advice line for advice, the TDIC analyst reminded him that wounds that have come in contact with blood or body fluids should be washed with soap and water. Additionally, the dentist must properly document the needlestick incident in a sharps injury log, which is required by law in most jurisdictions.

The dentist asked if it would be acceptable to contact the Source Patient and request that she be tested. He also inquired about his responsibility to cover all costs associated with patient testing. The analyst informed the dentist that it was recommended that the source patient be sent for testing and discussed initiating a claim to cover the source test under his professional and dental liability insurance policy of the TDIC.

Risk mitigation through exposure plans

Due to the potentially serious consequences of a needlestick incident, the Cal/OSHA Bloodborne Pathogen Standard requires dental practices of all sizes to have post-exposure plans in place. The essential elements of the plan include:

  • Immediate reporting of a needlestick injury to the dentist.
  • Forms documenting the exposure and, if necessary, the refusal of the employee or the source patient of a medical evaluation or test.
  • A diary of sharps injuries.
  • A pre-screened physician from the Medical Provider Network (MPN), the referral list provided by the Workers’ Compensation body, who can assess the exposed dental professional within 24 hours.

The TDIC advises dentists to report any incidents involving sharp objects or needle sticks to their workers’ compensation and malpractice insurance carriers for coverage of employee testing and source patient testing. Employers are required to pay for any medical treatment related to exposure to a blood-borne pathogen. However, all workers’ compensation policies, including TDIC’s, cover this for employees in the event of a needle stick injury.

Needle sticks: common but preventable

Although needlestick injuries among dental employees are common, training and safety protocols can help prevent them. “I typically see needlestick injuries from employees moving too quickly when recapping used needles,” notes Karen Schaffner, worker’s compensation manager for TDIC. Injuries frequently occur when instrument trays break following a procedure, in a recurring pattern of rushing to clean up and get ready for the next patient.

Your security obligations

To help reduce the risk of needlestick accidents and exposure to bloodborne pathogens, dentists are required to use “standard precautions” and have a pre-exposure control plan with details of employee protection measures. This plan should specify the use of a combination of engineering controls and work practices.

Work practice controls include:

  • Personal protective clothing.
  • Training in the use and disposal of sharps, including not bending or breaking needles prior to disposal.
  • Medical surveillance and vaccinations against hepatitis B.
  • Signs and labels.

Technical checks include:

  • Safety syringes designed to eliminate recapping and needle removal after use.
  • Sharps containers.
  • Strict compliance with the “full” line on containers for sharp objects.

Other resources to support your practice

In the State of California, employers are required to provide a form DWC-1 to an employee to be completed within one business day of becoming aware of a work-related injury or illness. TDIC and CDA offer additional resources for education, training, and information on compliance with Cal/OSHA requirements for managing exposure to bloodborne pathogens.

TDIC policyholders can log in to to access:

  • A downloadable form to document an employee’s refusal of post-exposure evaluation.
  • Easy ways to initiate a quote or request assistance with workers’ compensation insurance designed for dental practices.
  • A workers compensation claim kitwhich includes important required forms and postings such as DWC-1, DWC-7 and Form 5020.

Policyholders who have not yet created an online access account can do so at

CDA members can log on to to access downloadable resources:

Members also have access to affordable online training:

Take the time to explore the tools and expertise available through organized dentistry. Then, develop your exposure plan with your team and pursue blood-borne pathogen training that protects you and your practice team. Whenever TDIC policyholders or CDA members have questions about exposure to blood-borne pathogens or other compliance issues, the TDIC Risk Management Advice Line TDIC is ready to offer expert advice.

The TDIC Risk Management Advice Line is a benefit of CDA membership. Schedule a consultation with an experienced risk analyst or call 1.877.269.8844. Reprinted with permission from the California Dental Association, copyright July 2022.


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