blue line

Dental Industry Fit Testing Requirements: Reducing Exposure Amid COVID-19

EH&S Compliance, Health & Safety Training, Industrial Hygiene

Written by: Virginia McCormick, NES, Inc.

As businesses across the U.S. attempt to reopen safely, dental practices have begun the process of reassessing their needs to provide safe treatment.


Dental Industry Fit Testing Requirements Highlighted as Practices Reopen

As the world began to shut down due to the spread of COVID-19, on March 16, 2020 the American Dental Association recommended dentists postpone elective procedures. The Association’s recommendation was further supported by the Centers for Disease Control and Prevention (CDC). But now that many parts of the country are in the process of reopening, dental practices are beginning to reopen for regular business.

For general industry post-COVID-19 reopening information, see our recent blog CDC Guidelines to Creating and Maintaining Healthy Workspaces After COVID-19.

The virus that causes COVID-19 is thought to be spread primarily through respiratory droplets, termed aerosols, and dental practices often engage in procedures that generate aerosols, such as teeth cleaning and fillings. As a result, the Occupational Safety and Health Administration’s (OSHA’s) guidance on preparing workplaces for COVID-19 places dental health-care personnel (DHCP) in the very high exposure risk category.

Because of this, many DHCP are starting to employ the use of disposable filtering facepiece respirators, otherwise known as N95 masks, when available. While face masks and shields have been a staple of the industry, the increased risk of COVID-19 spreading via the dental industry is projected to result in a surge in mask usage overall in dentist offices around the country.


Fit testing is required both federally and at the state level to ensure employees are properly protected when performing their duties while wearing a respirator.


California dental offices must be sure to follow federal and State regulations regarding the use of respirators in the workplace so that their staff and patients are protected properly. In order to avoid the spread of COVID-19 or costly fines to the practice itself, dental industry fit testing requirements should be a top priority for offices reopening for regular business.


Fit Testing: A Brief Overview

Fit testing is the process of ensuring that the seal between a respirator and the wearer’s face is properly formed. As a respirator cannot protect a wearer if it does not fit correctly, fit testing is vital to ensuring employee safety. Fit testing is required by OSHA before a user wears a mandatory respirator on the job and, under normal circumstances, on an annual basis thereafter.

While annual fit testing has been temporarily waived during the pandemic, initial fit testing requirements have not. This means staff that have recently been required to wear masks must still be provided fit testing. In addition, employees being fit tested must have received medical clearance for wearing respiratory protection prior to fit testing.

In the post-COVID-19 reopening period, many workplaces are beginning to require respirator use and are therefore are required to provide fit testing. This includes dental industry practices, but it may also include industries not typically associated with facial masks, such as pet groomers or office-based businesses. There are two types of fit testing: qualitative and quantitative.

The qualitative testing method uses the wearer’s sense of taste or smell to detect leakage into the respirator. During this form of testing, the wearer is exposed to either a sweet- or bitter-smelling substance, commonly saccharin or denatonium. While this method does not measure the amount of leakage, it is normally used to test half-mask respirators such as N95s.

By comparison, quantitative testing uses a machine to measure the actual amount of leakage. This method does not rely on the wearer’s sense of taste or smell to detect leakage. The respirators used during this type of fit testing will have a probe attached to the facepiece that will be connected to the machine by a hose. This type of fit testing can be used for any type of tight-fitting respirator.

NES provides a 2-hour webinar that covers OSHA’s Respiratory Protection standard. For more information or to register for an upcoming session, check out the course listing here.


Dental procedures, such as teeth cleaning and cavity fillings, often produce aerosols. To ensure dental staff are properly protected from these aerosols, fit testing is implemented.


Dental Industry Fit Testing Regulatory Requirements

Use of respiratory protection is part of a comprehensive Respiratory Protection Program that must include medical exams, fit testing, and training in order to meet the requirements of OSHA’s Respiratory Protection standard (29 CFR 1910.134). As the dental industry falls under these requirements, fit testing is required.

Like the federal requirements, Cal/OSHA also requires an employer that requires respirator use to have a written Respiratory Protection Program and provide fit testing for affected employees. Cal/OSHA regulations are covered under Aerosol Transmissible Diseases (8 CCR 5199) and Respiratory Protection (8 CCR 5144).

Dental industry standard precautions, like hand hygiene and cough etiquette, are still vital. However, CDC has stated that there is currently, “no data available to assess the risk of SARS-CoV-2 transmission during dental practice or to determine whether DHCP are adequately protected when providing dental treatment using Standard Precautions.” As part of the control efforts, CDC recommends that dental staff should wear face masks at all times while they are in the dental setting.

Practices that do not properly follow state and federal respiratory protection requirements may incur heavy fines. Respiratory protection violations are very common, even during times without a pandemic. In 2019, respiratory protection made the top five list for OSHA’s most commonly issued citations.

And while failure to comply with proper respiratory protection procedures may be financially costly, health and safety missteps during a pandemic can result in repercussions that go beyond financial concerns. Essentially, dental industry fit testing requirements have been put in place to make sure that regular teeth cleanings do not end up sending staff and patients to the hospital for more serious reasons.


Failure to properly fit test employees can be both financially and morally costly in times of a pandemic.


NES Helps Practices Adhere to Dental Industry Fit Testing Requirements

In order to aid in the industry’s reopening and restructuring efforts, CDC has released interim guidelines for dental practices. The guidelines outline several elements DHCP should consider in the coming months, such as encouraging patients to postpone non-urgent dental visits, implementing telephone triage prior to emergency dental treatment, employing patient scheduling and flow protocols to minimize exposure, and encouraging staff and patients to stay home if sick.

CDC also advises that all DHCP, “regularly consult state dental boards or other regulating agencies for requirements specific to local jurisdictions.” Like many other factors of the reopening period, information is changing rapidly, and dentistry professionals need to keep up to date with local specifics.

As a leader in health and safety training, NES is no stranger to fit testing requirements. NES has been providing EH&S and industrial hygiene services on behalf of a wide array of public and private businesses and government agencies for the past 30 years.

NES provides qualitative and quantitative fit testing services at our office in Folsom, CA and on-site at clients’ facilities. If you have questions regarding respiratory protection, fit testing, and/or safety oversight during the global pandemic, please contact NES at 916-353-2360 / 800-637-2384 or via email at



The Guardian: Coronavirus: the week the world shut down

ADA News: ADA recommending dentists postpone elective procedures

CDC Recommendation: Postpone Non-Urgent Dental Procedures, Surgeries, and Visits

Capital Public Radio: Double The Masks And Eyewear: California Dentists Open Again For Cleanings

CDC: How COVID-19 Spreads

OSHA: COVID-19 – Control and Prevention / Dentistry Workers and Employers

CDA: Personal Protective Equipment during the COVID-19 Pandemic

29 CFR 1910.134

8 CCR 5199

8 CCR 5144

OSHA: Transcript for the OSHA Training Video Entitled Respirator Fit Testing

CDC: Dental Industry Standard Precautions

CDC: Interim Infection Prevention and Control Guidance for Dental Settings During the COVID-19 Response