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CDA members are asking how the state’s reopening will apply to dental practices.

Here, CDA Practice Support answers members’ top questions about physical distancing, patient screening, the use of face coverings and other requirements that will continue in health care settings after June 15.

1. Must we continue to screen patients and take temperatures?

Yes. Patient screening and temperature taking are recommended in the CDC guidance for dental practice. Employers are required by Cal/OSHA to implement controls to limit the COVID-19 transmission, and patient screening is considered a control.

2. Do vaccinated patients have to wear masks while in the practice?

Yes. CDC recommendations for fully vaccinated individuals clearly state that the recommendations do not apply to health care facilities. As a best practice, refresh patient communications and signage.

3. Do vaccinated staff have to wear masks while at work?

Yes. CDC guidance for vaccinated healthcare personnel state that PPE recommendations are unchanged. The Cal/OSHA emergency temporary standard continue to require mask use by all employees.

4. Are respirators still required to be used in the practice?

Yes, for aerosol generating procedures according to CDC guidance for dental practices and the Cal/OSHA emergency temporary standard.

5. Is physical distancing still required?

Yes, as required by Cal/OSHA.

6. Are barriers still required?

Yes, as required by Cal/OSHA.

7. Can the Cavitron and other aerosol generating devices be used?

There are no rules or regulations restricting these devices if they are necessary to perform dental treatment. However, Cal/OSHA requires an employer to do a COVID-19 risk assessment and to mitigate those risks to the extent feasible. The employer should describe the mitigation elements in their COVID-19 prevention/addendum to the Injury and Illness Prevention Plan. These elements can include but are not limited to respirators, high-volume evacuation and portable air filtration units.

8. Does CDA still recommend patients rinse with hydrogen peroxide rinse prior to any dental procedure?

Neither CDC, CDA or the ADA recommend a pre-rinse as a COVID-19 prevention method. The CDC states, “Although SARS-CoV-2 was not studied, PPMRs (preprocedural mouth rinses) with an antimicrobial product . . . may reduce the level of oral microorganisms in aerosols and spatter generated during dental procedures.”

The Department of Consumer Affairs on March 30 issued a new C.E. extension waiver for California-licensed dental professionals whose active licenses expire between March 31, 2020, and May 31, 2021. Licensees now must satisfy any waived renewal requirements within six months of the order — by September 30, 2021 — unless the waiver is further extended.

The March 30 order rescinds the DCA’s previous three C.E. extension waivers issued in October 2020, December 2020 and February 2021. Affected licensees now have additional time to complete necessary continuing education courses and to take and pass the required examinations to renew their licenses.

Licensees must still comply with other renewal requirements, including completing and submitting required renewal forms to the governing licensing agency and paying renewal fees by their respective due dates.
The waivers issued by DCA during the pandemic are a result of CDA’s continued advocacy efforts to support dental professionals impacted by COVID-19.

Gov. Gavin Newsom’s state-of-emergency order on March 4, 2020, granted the Department of Consumer Affairs the authority to waive statutory or regulatory professional licensing requirements as part of the state’s response to the COVID-19 pandemic.

Dentists registered with the U.S. Drug Enforcement Administration should be aware that the DEA is no longer sending renewal notices by U.S. Postal Service as of last June. Instead, registrants will receive renewal notifications by email and should confirm that their email address on file is current.

The California Division of Occupational Safety and Health’s current regulations on COVID-19 related screening, testing and quarantining apply to dentists, dental team members and other health care workers in California who are fully vaccinated against the novel coronavirus, as well as to fully vaccinated patients who enter health care settings.

Dental offices, therefore, must continue to screen all patients and dental staff, including those who are fully vaccinated, for COVID-19 and follow other Cal/OSHA regulations on COVID-19 prevention, such as using proper personal protective equipment and requiring that patients wear masks and socially distance, until Cal/OSHA amends its COVID-19 regulations. These infection prevention procedures must be documented in a written plan, as required by Cal/OSHA.

Following an uptick in vaccine supply and administration, news outlets earlier this month widely reported the U.S. Centers for Disease Control and Prevention’s interim public health recommendations for fully vaccinated individuals. The CDC considers a person fully vaccinated if more than two weeks have passed since they received a single-dose vaccine, like the Janssen COVID-19 Vaccine by Johnson & Johnson, or the second in a two-dose vaccine series.

But the news created confusion both for health care workers and patients seeking care because those recommendations are intended only for non-health-care settings and allow fully vaccinated people to refrain from observing social distancing and wearing masks in some situations. They also allow fully vaccinated individuals to refrain from COVID-19 testing and quarantine following exposure to someone with confirmed or suspected COVID-19.
The CDC issued separate recommendations for fully vaccinated individuals in health care settings, and those recommendations more closely align with current Cal/OSHA regulations. Cal/OSHA expects to update its regulations to address exposure protocols for fully vaccinated employees later this year. Until then, dental practices should continue to:

– Screen all patients and staff for COVID-19 and record employees’ COVID-19 symptoms, exposure or positive test, regardless of whether the employee was exposed in the dental office (CDA has a tracking form)
– Ask fully vaccinated staff who have had close contact with someone who tested positive for or has symptoms of COVID-19 to quarantine
Ensure six feet of physical distancing
– Provide employees with proper personal protective equipment, including respirators for aerosol generating procedures
– Follow all other Cal/OSHA COVID-19 prevention regulations
Cal/OSHA will enforce annual fit requirements for tight-fitting respirators.

Medical evaluation and fit testing is a Cal/OSHA requirement for use of most respirators, including the N95. Employers are required to provide an initial fit test and an annual fit test. “Annual” means one year from the last fit test for the specific model being used.
Although OSHA temporarily suspended the annual fit test in April 2020 due to the public health crisis, Cal/OSHA announced it would continue enforcing the annual fit-test requirement. The agency will allow a 90-day delay for meeting annual fit-testing requirements provided there are no changes in an employee’s physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery or an obvious change in body weight.

Fit testing is a two-step process that is usually performed by two different entities: The medical evaluation occurs first and is followed by the actual fit test. A licensed health care professional must perform the medical evaluation using a questionnaire to gather specific required information.

Dental practices that do not receive consistent shipments of the types and sizes of respirators they ordered should document those events. Cal/OSHA only considers NIOSH-certified respirators, such as N95s, as appropriate protection when respiratory protection is required in the dental office.

The CDA Practice Support resource N95 Fit Testing Requirements explains how to locate a medical evaluator and fit tester and all the steps required as part of the fit test.