Infection Prevention and Control for Dentists during the COVID-19 Pandemic

During the COVID-19 pandemic, infection prevention and control (“IPAC”) in dental offices has taken on a new level of significance in the public consciousness. While it has always been important for dentists to implement and maintain appropriate IPAC measures, social distancing and global efforts to flatten the curve require increased precautions. Dentists who continue to provide dental services during Ontario’s state of emergency should be aware that they may potentially be subject to complaints to the Royal College of Dental Surgeons of Ontario (“RCDSO”) relating to their IPAC practices.

Emergency and urgent dental treatment have been deemed essential services during the COVID-19 pandemic. Dentists who provide such services are required to properly use personal protective equipment (“PPE”). As COVID-19 is transmitted through aerosols and droplets, the RCDSO has urged dentists to avoid aerosol generating procedures as much as possible, including treatment involving high-speed and low-speed handpieces. Where an emergency or urgent condition cannot be managed without generating an aerosol, dentists and all clinical staff are required to use even further enhanced PPE. The RCDSO has published more specific guidance on its website.

With respect to potential complaints, patients could allege that dentists did not use adequate PPE, or failed to use PPE effectively. Complaints could relate to touching a phone or lifting a mask during the course of an appointment. Patients might also complain about a perceived lack of cleanliness or sterilization, an inability to socially distance with other individuals in the dental clinic, or a lack of hand sanitizer. Complaints may arise even where there has been no direct contact with a dentist, or where no treatment has been rendered. Inadequate IPAC and PPE measures could also be linked to allegations that patients contracted COVID-19 from their dentist.

Due to the seriousness of COVID-19 and the high risk of harm to the public, the RCDSO could potentially impose interim orders to address more significant concerns relating to IPAC and PPE. The RCDSO could even impose an interim suspension, which would prevent a dentist from practicing dentistry in any capacity until the underlying matter is addressed at a potential disciplinary hearing.

Dentists should take extra precautions if they are continuing to practice during the COVID-19 pandemic, and should take all complaints very seriously.

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