NEWS FLASH: CDPH Requires Weekly COVID-19 Testing of Unvaccinated Healthcare Employees

On July 26, 2021, the California Department of Public Health (CDPH) released a State Public Health Officer Order mandating that all healthcare facilities, including dental offices, ensure that unvaccinated personnel undergo at least weekly COVID-19 testing and wear appropriate personal protective equipment (PPE).

Current COVID-19 Trends

According to the State Order, California is currently experiencing the fastest increase in COVID-19 cases during the entire pandemic with 11.2 new cases per 100,000 people per day, with case rates increasing fivefold within two months. The Delta variant, which is the dominant strain causing most of these new infections in California, is up to two times more transmissible and may cause more severe illness. Additionally, unvaccinated persons are more likely to get infected and spread the virus, which is transmitted through the air. Most current hospitalizations and deaths are among unvaccinated persons. Therefore, previous workplace standards in healthcare settings, such as universal mask requirements for all staff, are not proving sufficient to prevent transmission of the Delta variant, especially among unvaccinated personnel.

Requirements of the State Public Health Officer Order

All healthcare facilities, including dental offices, have until August 23, 2021, to comply with the following requirements stipulated in the State Order:

• Vaccine verification: Dental employers must verify that their workers[1] are fully vaccinated against COVID-19, and must retain written records that employees are fully vaccinated. Workers who are not fully vaccinated, or for whom vaccine status is unknown or documentation is not provided, must be considered unvaccinated. Facilities must have a plan for tracking worker vaccination status with records made available, upon request, to the local health authorities.
• Testing:Dental personnel who are not fully vaccinated are subject to weekly COVID-19 testing. Testing can be either antigen or PCR, and must have approval from the US Food and Drug Administration (FDA). Unvaccinated workers are not exempt from the testing requirement even if they have a medical contraindication to vaccination, since they are still potentially able to spread the illness. Previous history of COVID-19 infection(s) from which the individual recovered more than 90 days earlier, or a previous positive antibody test for COVID-19, do not waive this requirement for testing.
• Personal Protective Equipment (PPE): All unvaccinated dental personnel are required to wear FDA-cleared surgical masks, at a minimum, in indoor settings anywhere they are working with another person. Note that all employees, patients, and visitors must continue to wear facemasks in healthcare settings.

Dental offices with unvaccinated personnel required to undergo workplace diagnostic screening testing should have a plan in place for tracking test results and conducting workplace contact tracing. If requested, they must report specified results to local public health departments. There are no specific requirements on how offices must keep test results, but software apps, online databases, or hardcopy forms may all be used. Keep in mind that employee test results must be kept confidential.

Employee vaccination status, employee testing tracking, and contact tracing forms can be accessed here or can be downloaded from our website.

As the pandemic evolves, OSHA Review will continue to provide guidance to our OSHA Review clients as new information and clarification from state and federal agencies becomes available. 

[1] “Worker” refers to all paid and unpaid persons serving in healthcare, other healthcare or congregate settings who have the potential for direct or indirect exposure to patients/clients/residents or SARS-CoV-2 airborne aerosols. Workers include, but are not limited to, nurses, nursing assistants, physicians, technicians, therapists, phlebotomists, pharmacists, students and trainees, contractual staff not employed by the healthcare facility, and persons not directly involved in patient care, but who could be exposed to infectious agents that can be transmitted in the health care setting (e.g., clerical, dietary, environmental services, laundry, security, engineering and facilities management, administrative, billing, and volunteer personnel).

Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.