Nevada OSHA Vs. Federal OSHA: What to know.
- Tooth Nerd
- Sep 17
- 4 min read
Compliance Differences for Dental Practices
Nevada operates under its own OSHA-approved state plan (Nevada OSHA), which must be “at least as effective as” federal OSHA. Dental practices in Nevada must follow both federal standards (adopted by Nevada) and any Nevada-specific rules that go further.
1. Required Employee Safety Training
Federal OSHA:
No general rule requires every small business to have a written safety program.
Training is mandated by specific standards:
Bloodborne Pathogens (29 CFR 1910.1030) — initial and annual training
Hazard Communication (29 CFR 1910.1200) — at hire and when new chemicals are introduced
PPE (29 CFR 1910.132) — when provided
Training must be understandable to employees and documented.
Nevada OSHA:
Requires a Written Workplace Safety Program for employers with more than 10 employees (NAC 618.538).
This written plan must include an employee safety training program, methods for identifying and correcting hazards, and procedures for training new and temporary employees before they start work.
If a practice has 25 or more employees, it must also establish a safety committee (NAC 618.540).
Training must be provided in a language and format employees understand.
Dental impact:Even though federal OSHA does not require a general written program, Nevada OSHA does—so larger dental practices must create and maintain a documented training plan and safety program.
2. Inspection and Enforcement
Federal OSHA:
Dental practices are considered low hazard (NAICS 621210).
Usually inspected only if there is a complaint, referral, serious injury, or fatality.
No federal requirement to present a general safety program during inspection.
Nevada OSHA:
Uses the same triggers (complaints, incidents, fatalities) but will expect to see the required written safety program and training documentation if the practice has more than 10 employees.
Nevada citations and penalties are issued through the state Division of Industrial Relations and appealed to the Nevada Occupational Safety and Health Review Board.
Dental impact:Nevada OSHA inspectors will look for items (written plan, training records) that federal OSHA would not request in a small clinic.
3. Recordkeeping and Reporting
Federal OSHA:
Dental offices are partially exempt from OSHA 300 logs (29 CFR 1904.2, NAICS 621210).
Must still report:
Any work-related fatality within 8 hours
Any in-patient hospitalization, amputation, or loss of eye within 24 hours
Must maintain a Sharps Injury Log under the Bloodborne Pathogens standard.
Nevada OSHA:
Follows the same partial exemption: dental offices do not routinely maintain OSHA 300 logs unless specifically asked.
Follows the same reporting requirements (fatalities and serious injuries) through the state OSHA office.
Dental impact:Day-to-day OSHA injury logs are usually not required, but dental offices must still report serious incidents immediately and keep sharps and exposure records internally.
4. Infection Control and Bloodborne Pathogens
Federal OSHA:
Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to all dental staff with exposure to blood or saliva. Requires:
Written Exposure Control Plan
Hepatitis B vaccination at no cost
Universal precautions, sharps safety, PPE, post-exposure follow-up
Annual training and a Sharps Injury Log
Hazard Communication Standard (29 CFR 1910.1200) applies to chemical use in dental offices.
PPE (29 CFR 1910.132) and Respiratory Protection (29 CFR 1910.134, if respirators are used) also apply.
Nevada OSHA:
Has adopted these federal standards by reference — Nevada OSHA enforces 29 CFR 1910.1030, 1910.1200, 1910.132, and 1910.134 as state law.
Also requires infection control practices to be included in the written safety program.
Separately, the Nevada State Board of Dental Examiners requires compliance with the CDC Guidelines for Infection Control in Dental Health-Care Settings (NAC 631.178).
The Dental Board audits for sterilization, waterline maintenance, and spore testing — which go beyond OSHA requirements.
Dental impact:Nevada dental offices must meet all OSHA bloodborne and chemical safety rules and comply with CDC infection control guidelines as state-mandated dental practice standards.
5. Nevada-Specific Rules Beyond Federal OSHA
Written Safety Program – required if >10 employees (NAC 618.538).
Safety Committee – required if >25 employees (NAC 618.540).
Training for Temporary Staff – must receive site-specific safety training before beginning work (NAC 618.544).
Training Must Be Understandable – explicitly required in Nevada rules.
CDC Infection Control Compliance – mandatory through dental board regulation (NAC 631.178).
Summary
Area | Federal OSHA | Nevada OSHA |
Written safety program | Not required | Required if >10 employees |
Safety committee | Not required | Required if >25 employees |
Training | Topic-specific | Broader, structured plan required |
Recordkeeping | OSHA 300 log exemption | Same exemption |
Infection control | Bloodborne Pathogens standard | Same + CDC dental guidelines required |
Temporary staff training | Implied duty | Explicitly required |
Bottom line:Federal OSHA provides the baseline rules, but Nevada OSHA adds state-specific requirements for written programs, committees, and training structure. Dental offices in Nevada must go beyond federal minimums to stay compliant.
Federal OSHA Regulations (Apply Nationwide, Including Nevada)
Bloodborne Pathogens Standard (29 CFR 1910.1030)https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030
Hazard Communication Standard (29 CFR 1910.1200)https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
Personal Protective Equipment (PPE) (29 CFR 1910.132)https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132
Respiratory Protection (29 CFR 1910.134)https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134
OSHA Recordkeeping (29 CFR Part 1904)https://www.osha.gov/recordkeeping
OSHA Reporting Severe Injurieshttps://www.osha.gov/report
Dentistry Industry Guidance (OSHA)https://www.osha.gov/dentistry
Nevada OSHA Regulations (State Plan)
Nevada OSHA State Plan Overview (U.S. DOL)https://www.osha.gov/stateplans/nv
Written Workplace Safety Program — NAC 618.538https://www.leg.state.nv.us/nac/NAC-618.html#NAC618Sec538
Safety Committee Requirements — NAC 618.540https://www.leg.state.nv.us/nac/NAC-618.html#NAC618Sec540
Training for Temporary Employees — NAC 618.544https://www.leg.state.nv.us/nac/NAC-618.html#NAC618Sec544
Nevada OSHA Reporting (Fatalities/Injuries)https://dir.nv.gov/OSHA/Reporting_Requirements/
Nevada OSHA Consultation and Training (SCATS)https://www.4safenv.state.nv.us/
Nevada Dental Board Regulations
Infection Control Standards — NAC 631.178(Adopts CDC Guidelines for Infection Control in Dental Health-Care Settings)https://www.leg.state.nv.us/nac/NAC-631.html#NAC631Sec178
Nevada State Board of Dental Examinershttps://dental.nv.gov
CDC Guidelines for Infection Control in Dental Health-Care Settings (2003)https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm
