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New Mexico

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Federal Compliance Guidelines for Dental Practices

Last Reviewed 10/27/2025

Protecting your team, your patients, and your license starts with knowing the federal standards that every dental practice must meet.
 

Dental practices operate in one of the most regulated environments in healthcare. Federal agencies such as OSHA, HHS, CDC, and the FDA establish national rules that define safe, ethical, and compliant dental care. Whether you’re a single-location practice or a multi-state DSO, these federal frameworks create the foundation upon which all state-specific regulations are built.
 

The five pillars of federal compliance in dentistry are:

  1. OSHA – Workplace Safety and Hazard Communication

  2. HIPAA – Patient Privacy and Data Security

  3. Infection Control – Universal Precautions and CDC Standards

  4. Radiation Safety – ALARA Principles and Equipment Performance

  5. Emergency Preparedness – Response Planning and Team Readiness

 

1. OSHA Compliance in Dental Settings
 

Overview
 

The Occupational Safety and Health Administration (OSHA) sets national standards to protect dental employees from workplace hazards such as bloodborne pathogens, hazardous chemicals, ergonomic injuries, and sharps exposure. Every dental employer must maintain written safety programs, provide training, and document compliance activities.
 

Key Federal Requirements

  • Bloodborne Pathogens Standard (29 CFR 1910.1030):
    Requires an Exposure Control Plan, annual training, use of safer sharps, and free hepatitis B vaccinations.

  • Hazard Communication Standard (29 CFR 1910.1200):
    Mandates a Hazard Communication Plan, Safety Data Sheets (SDS), chemical labeling, and staff training.

  • Personal Protective Equipment (PPE) Standard:
    Employers must assess and provide appropriate PPE—gloves, masks, eyewear, gowns—and train on proper use.

  • Ergonomic and Injury Prevention:
    Practices must identify repetitive strain risks and maintain OSHA injury logs (Form 300).

 

Documentation & Training

  • Written plans (BBP, HazCom, IIPP or Safety Program)

  • Employee exposure incident logs and post-exposure protocols

  • Annual training with proof of attendance

 

Common Pitfalls


Failure to update annual training, missing SDS binders, and outdated exposure control plans are among the top citations in dental OSHA audits.
 

2. HIPAA & Federal Privacy Requirements
 

Overview


The Health Insurance Portability and Accountability Act (HIPAA) is enforced by the U.S. Department of Health and Human Services (HHS) through the Office for Civil Rights (OCR). It safeguards patient information (PHI) in all formats—paper, electronic, and verbal.
 

Key Federal Rules

  • Privacy Rule: Governs how PHI is used and disclosed.

  • Security Rule: Requires technical, physical, and administrative safeguards for ePHI.

  • Breach Notification Rule: Mandates reporting of any unauthorized PHI disclosure.

 

Practice Obligations

  • Maintain written HIPAA policies and procedures

  • Conduct an annual Security Risk Assessment

  • Appoint a Privacy Officer and Security Officer

  • Train all staff upon hire and annually

  • Sign and maintain Business Associate Agreements (BAAs) with vendors

 

Common Pitfalls
 

Improper disposal of records, unsecured computers, weak passwords, and lack of encryption are frequent violations. HHS fines can reach millions of dollars per breach event.
 

3. Infection Control Standards
 

Overview
 

Federal infection control expectations stem from the Centers for Disease Control and Prevention (CDC) and OSHA’s Bloodborne Pathogen Standard. Every dental practice must adhere to the CDC’s Guidelines for Infection Control in Dental Health-Care Settings (2003) and periodic updates.
 

Core Elements

  • Standard Precautions: Treat every patient as potentially infectious.

  • Engineering Controls: Use sharps containers, dental unit waterline management, and sterilization monitoring.

  • Work Practice Controls: Proper hand hygiene, use of PPE, instrument cleaning, sterilization, and safe injection practices.

  • Environmental Cleaning: Disinfect clinical contact surfaces between patients.

 

Documentation & Monitoring

  • Written infection control plan and sterilization logs

  • Weekly spore testing records

  • Waterline monitoring and maintenance

  • Annual infection control training

 

Common Pitfalls- Failure to perform weekly spore testing, improper sterilization packaging, and overlooking dental waterline maintenance.
 

4. Radiation Safety in Dentistry
 

Overview
 

Federal radiation safety oversight is shared by the U.S. Food and Drug Administration (FDA) and the Nuclear Regulatory Commission (NRC). While most operational rules are enforced at the state level, federal standards define how equipment is manufactured, operated, and maintained.
 

Core Federal Standards

  • FDA Performance Standards (21 CFR 1020.30-31): Regulate dental X-ray machine design and radiation output.

  • ALARA Principle (“As Low As Reasonably Achievable”): Minimizes exposure for patients and staff.

  • Operator Protection: Use of lead barriers, dosimeters where required, and safe positioning (6 feet and 90-135° from beam).

  • Equipment Quality Assurance: Regular calibration, maintenance, and testing per manufacturer and state requirements.

 

Documentation & Training

  • Equipment maintenance and inspection logs

  • Radiography technique chart and exposure protocols

  • Annual radiation safety training for all operators

 

Common Pitfalls- Expired equipment registrations, missing QA logs, and inadequate shielding or operator distance awareness.
 

5. Emergency Preparedness & Medical Readiness


Overview
While no single federal law dictates dental emergency preparedness, multiple agencies—OSHA, CDC, ADA, and DHS—establish expectations for medical and workplace emergencies. Every practice must maintain an Emergency Action Plan and ensure staff readiness for both medical and environmental crises.
 

Core Requirements

  • OSHA Emergency Action Plan (29 CFR 1910.38): Procedures for evacuation, reporting fires, and contacting emergency services.

  • Medical Emergencies in Dentistry: Maintain an emergency kit, AED, oxygen tank, and train staff in Basic Life Support (BLS).

  • CDC Guidance: Infection and biohazard response, including pandemic preparedness.

  • Homeland Security (DHS): Encourages all healthcare facilities to have continuity and disaster response plans.

 

Documentation & Training

  • Written Emergency Action Plan and posted evacuation routes

  • Annual mock drills and CPR certification

  • Maintenance logs for emergency medications and AED checks

 

Common Pitfalls- Expired emergency drugs, untrained front desk personnel, and lack of posted emergency numbers.
 

Why Federal Compliance Matters


Federal compliance isn’t just about avoiding penalties—it’s about building a culture of safety, trust, and accountability. A practice that masters federal requirements can more easily meet state-specific laws, pass inspections, and maintain operational integrity across multiple locations.
 

Next Steps for Dental Teams

  • Audit your OSHA, HIPAA, Infection Control, and Radiation Safety programs annually.

  • Document all training and review your written plans.

  • Conduct mock emergencies and incident response drills.

  • Use a centralized compliance platform—like Done Desk or Tooth Nerd Quick Start Programs—to manage documentation, renewals, and training.

 

Protect your practice. Empower your people. Stay compliant.
Explore the Quick Start Compliance Program for ready-to-use OSHA, HIPAA, Infection Control, and Radiation Safety plans built specifically for dental practices.

State Guidelines

New Mexico-Specific Information


Regulating Bodies


  • New Mexico Board of Dental Health Care (NMBOD) — regulates dental licensure, continuing education, anesthesia and sedation permits, infection control standards, and disciplinary enforcement under the New Mexico Statutes Annotated (NMSA) Chapter 61, Article 5A.

  • New Mexico Environment Department (NMED) — Radiation Control Bureau — oversees registration, inspection, and radiation safety for dental X-ray equipment.

  • New Mexico Occupational Health and Safety Bureau (NM OSHA) — operates an OSHA-approved state plan, covering both private- and public-sector employers.

  • New Mexico Department of Workforce Solutions (NMDWS) — administers labor compliance and safety support programs.


Licensing & Continuing Education


  • Dentists: Renew biennially; must complete 60 hours of continuing education per renewal cycle.
    CE must include:
    Infection control and ethics/jurisprudence.
    BLS/CPR certification
    from an approved provider.
    Anesthesia/Sedation permit holders must complete 6 hours of CE in anesthesia and emergency management.

  • Dental Hygienists: Renew biennially; must complete 30 hours of CE, including infection control and CPR.

  • CE may be obtained from ADA CERP, AGD PACE, or Board-approved providers.

  • Licensees must retain CE records for six years for audit.

  • Reference: 16.5.1 NMAC – Licensure and Continuing Education Requirements.


Workplace Safety (New Mexico OSHA)


  • New Mexico operates its own OSHA-approved state plan, administered by the Occupational Health and Safety Bureau within the Environment Department.

  • Dental practices must maintain written Exposure Control and Hazard Communication Plans, conduct annual Bloodborne Pathogens and chemical safety training, and ensure PPE compliance.

  • NM OSHA enforces standards equivalent to federal OSHA, including 29 CFR 1910.1030 and 1910.1200.

  • Safety and training documentation must be maintained for inspection.

  • NM OSHA provides free consultation and training services through its on-site consultation program.


Radiation Safety


  • All dental X-ray equipment must be registered with the NMED Radiation Control Bureau prior to operation.

  • Maintain Quality Assurance (QA) and Quality Control (QC) records, operator competency documentation, and radiation protection surveys.

  • Regulations are found in 20.3.1–20.3.20 NMAC (Radiation Protection Rules).

  • Only trained and authorized personnel may operate dental X-ray machines.

  • NMED inspectors conduct periodic audits to verify compliance with state radiation standards and federal exposure limits.


Infection Control & Patient Safety


  • New Mexico dental offices must adhere to CDC infection control guidelines and OSHA Bloodborne Pathogens standards.

  • Maintain written sterilization and disinfection procedures, PPE policies, and post-exposure protocols.

  • Weekly biological (spore) testing of sterilizers is required and must be documented.

  • Infection control training must occur at hire and annually thereafter for all clinical staff.

  • Noncompliance is considered unprofessional conduct under NMSA 61-5A-13.


Emergency Preparedness


  • Dental practices must have oxygen, emergency drugs, and equipment appropriate for their level of care.

  • A staff member with current BLS certification must be present during all patient treatment.

  • Sedation and anesthesia permit holders must maintain ACLS or PALS certification, conduct annual emergency drills, and maintain written protocols and logs.

  • Emergency preparedness is reviewed during permit renewals and complaint inspections.


Official Resources


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Dental Team Training Requirements in New Mexico


Overview


New Mexico dental practices are licensed by the New Mexico Board of Dental Health Care (Regulation & Licensing Department). Workplace safety is enforced by OHSB (NM OSHA). Dental X-ray registration, inspections, and operator safety are regulated by the New Mexico Environment Department (NMED) – Radiation Control Bureau under 20.3 NMAC.

All practices must also comply with HIPAA and CDC infection-control guidance. Dentists and hygienists complete Board-required continuing education (CE) each renewal cycle; assistants who expose radiographs must hold Board-recognized radiography training/credentials consistent with NMED operator-safety rules.


Dentist Training Requirements

Required Training


  • NM OSHA Bloodborne Pathogens & Hazard Communication (Annual): Written Exposure Control & HazCom plans; engineering controls, PPE, sharps safety, post-exposure protocols; documented annual training.

  • Infection Control (Annual): Follow CDC dental guidelines; sterilization and spore testing, waterline maintenance, hand hygiene, PPE, and exposure management; keep written SOPs.

  • Radiation Safety & X-ray Registration: Register dental X-ray units with NMED Radiation Control; maintain QA/QC tests, operator instructions, signage, ALARA practices, and inspection records.

  • CPR/BLS (Current): Required for active practice; ACLS/PALS if applicable to sedation level.

  • Continuing Education: Complete Board-required CE each renewal (strongly include infection control, ethics/jurisprudence, medical emergencies; opioid/pain management CE for DEA registrants).

  • HIPAA Privacy & Security: Workforce training, access controls, breach response, and documentation (consider NM data-breach obligations for businesses handling PII).


Recommended


  • Risk management & documentation (informed consent, adverse-event response).

  • Medical emergency preparedness (airway, anaphylaxis, syncope).

  • Leadership, harassment-prevention, and inclusive communication.

  • Cybersecurity for ePHI and ransomware defense.


Dental Hygienist Training Requirements

Required Training


  • NM OSHA BBP & HazCom (Annual).

  • Infection Control (Annual): CDC-aligned protocols; PPE, sterilization logs, exposure plan.

  • Radiography: Hygienists may expose radiographs with dentist authorization; follow NMED operator-safety rules and facility QA/QC under 20.3 NMAC.

  • CPR/BLS (Current).

  • Continuing Education: Complete Board-specified CE each renewal; keep certificates for audit (include infection control, ethics/jurisprudence, and patient-safety content).


Recommended


  • Periodontal instrumentation/calibration; local anesthesia/N₂O refreshers where permitted.

  • Ergonomics & musculoskeletal injury prevention.

  • HIPAA communications and secure teledentistry.

  • Medical emergency recognition and oxygen delivery basics.


Dental Assistant Training Requirements

Required Training


  • NM OSHA BBP & HazCom (Annual).

  • Infection Control & Sterilization (Initial + Annual).

  • Radiography (if taking X-rays): Documented radiography education/competency accepted by the NM Board of Dental Health Care (e.g., Board-approved/DANB RHS route) and compliance with NMED operator rules, ALARA, QA logs, and required signage.

  • Expanded Functions (if applicable): Complete Board-approved Expanded Function Dental Auxiliary (EFDA) training/permits for duties beyond basic chairside.

  • CPR/BLS (Current).

  • HIPAA Privacy & Security (Initial + periodic refresh).


Recommended


  • Chairside efficiency & four-handed dentistry; instrument processing QA.

  • Emergency preparedness drills and chemical spill response.

  • Customer service, service recovery, and patient comfort.


Front Desk & Administrative Staff Training Requirements

Required Training


  • HIPAA Privacy & Security: Minimum-necessary access, disclosures/authorizations, release-of-records, breach response; role-based access controls.

  • OSHA Awareness: General safety training for non-clinical staff working in healthcare settings (especially if they assist near clinical areas).


Recommended


  • Scheduling optimization, recall/broken-appointment protocols.

  • Insurance/billing compliance and financial communications.

  • Cybersecurity basics (phishing, passwords, device security).

  • De-escalation, service recovery, and patient experience.

  • Records retention timelines (state/federal).


Operational Best Practices (All Roles)


  • Keep written plans current: Exposure Control, Hazard Communication (SDS access), Infection Control/Instrument Reprocessing, Post-Exposure, Emergency Action Plan.

  • Sterilizer monitoring: Perform and log weekly biological (spore) tests; document maintenance and load tracking.

  • Radiation QA/QC: Collimation, shielding, technique charts, performance tests, operator instructions; keep NMED registration and inspection paperwork current.

  • Emergency drills: Document mock events (syncope, anaphylaxis, airway); check oxygen/AED/emergency kit monthly.

  • Maintain a compliance binder with NM OSHA/HIPAA training, CE, radiography credentials, and QA documents ready for inspection.


State References


  • New Mexico Board of Dental Health Care (RLD) — licensure, CE, permits, scope/rules

  • New Mexico OSHA (OHSB) — state OSHA plan, enforcement & consultation

  • NMED – Radiation Control Bureau (20.3 NMAC) — dental X-ray registration & radiation protection rules

  • CDC Infection Control in Dental Settings — sterilization, PPE, waterlines, exposure response

  • HIPAA — Privacy & Security Rules (45 CFR 164)



Make New Mexico compliance predictable and painless.
Train your team with Tooth Nerd’s OSHA/NM-OSHA, HIPAA, Infection Control, Radiation Safety, and role-specific CE. Automate reminders, track certificates, and stay inspection-ready year-round with Done Desk.

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Now that you know everything it's time to get started by training your people and operationalizing excellence with Done Desk! 

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