Under OSHA’s Bloodborne Pathogens Standard, dental offices with employees who have occupational exposure are required to maintain a written Exposure Control Plan. This is not an optional policy or a best-practice extra—it is a core OSHA compliance requirement for covered employers.
For dental practices, the plan should be site-specific and reflect the actual procedures, job roles, and exposure risks in your office. During an inspection, OSHA will typically request this documentation along with related training and recordkeeping requirements.
The good news is that compliance doesn’t have to be complicated. A strong dental exposure control plan is a clear written plan that explains how your office prevents exposure, trains employees and responds if an exposure incident occurs.
What Is an Exposure Control Plan?
An Exposure Control Plan is the written policy that supports your office’s compliance with the OSHA Bloodborne Pathogens Standard. In practical terms, it outlines:
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Which employees have occupational exposure
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Which tasks or procedures create risk
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What PPE and safety controls are used
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How training is handled
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What happens after an exposure incident
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How records are maintained and reviewed
A site-specific exposure control plan typically includes the following:
Exposure Determination - This section identifies job roles and tasks with occupational exposure. In many dental offices, that may include dentists, hygienists, assistants, and other clinical staff.
Methods of Compliance - This explains how your office reduces exposure risk by identifying engineering controls, work practice controls, PPE use, housekeeping / decontamination procedures, handling contaminated materials, regulated waste and labels/signage in your dental office.
Hepatitis B Vaccination and Post-Exposure Follow-Up - Your plan should describe how your office handles:
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Offering the Hepatitis B vaccine to employees with occupational exposure
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Declinations (if applicable)
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Post-exposure reporting and follow-up
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Medical evaluation and follow-up arrangements
Even if your staff know the process, OSHA requires it to be documented.
Exposure Incident Reporting Procedures - This should clearly state what happens immediately after an exposure incident, including who to report to, how the incident is documented, and how follow-up starts.
Employee Training and Documentation - Bloodborne pathogens training is not a one-time event. Your plan should identify who is trained, when training occurs, and how completion is documented.
Annual Review and Updates – Your exposure control plan should be reviewed and updated regularly (at least annually). If your practice has any changes like adding new procedures or adding new equipment it needs to be reflected in your policy.
If an OSHA inspector requests documentation and your office doesn’t have a written exposure control plan, it’s usually going to lead to citations. In many cases, the issue isn’t limited to one missing document. Offices that don’t have that often have gaps in employee training, Hepatitis B vaccine documentation, exposure incident reporting and other critical areas.
That is why it is best to treat your ECP as part of a complete compliance system, not a stand-alone policy.
What kind of fines could we be talking about?
As of February 1, 2026, OSHA’s published federal maximum penalties shown on OSHA’s penalties page include:
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Serious / Other-than-Serious / Posting Requirements: up to $16,550 per violation
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Failure to Abate: up to $16,550 per day beyond the abatement date
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Willful or Repeated: up to $165,514 per violation
Important note: those are maximums, and actual proposed penalties depend on how OSHA classifies the issue and the facts of the inspection. But even for smaller practices, citations are disruptive, time-consuming, and expensive to deal with.
Dental OSHA Compliance Made Practical
Most dental offices don’t need a complicated corporate compliance program. They need a clear, organized, site-specific system that matches how their office actually operates.
At Oshaguard, we create OSHA compliance manuals for healthcare and dental facilities with practical, site-specific policy formats designed to make compliance manageable. If your bloodborne pathogens documentation is outdated, too generic, or incomplete, this is a smart time to tighten it up and get your office back on track.
