ADA comments on OSHA rule requiring businesses with 100 or more employees to institute vaccine, testing policies

 

Association concerned mandate could exacerbate staffing shortages

The ADA is concerned that the Occupational Safety and Health Administration’s emergency temporary standard mandating employers with 100 or more employees to require their employees be vaccinated against COVID-19 or submit to regular masking and testing could potentially impede patients’ access to oral health care. 

In a Dec. 1 letter to Douglas L. Parker, assistant secretary of labor, Occupational Safety and Health Administration, ADA President Cesar R. Sabates, D.D.S., and Executive Director Raymond A. Cohlmia, D.D.S., said because of low COVID-19 infection rates in dentistry and high vaccination rates of dental personnel, requiring dental practice owners to institute a mandatory vaccination and testing policy will likely have “little impact” on the safety of dental personnel and patients. The Association is concerned, however, that such a mandate could have the unintended effect of exacerbating dental team shortages which would limit dentists’ ability to see more patients and impede access to essential health care. 

In the letter, Drs. Sabates and Cohlmia told OSHA that research indicates that infection rates among dentists and dental teams are “very low — far lower than for other health care workers, such as nurses and physicians, and even lower than in the general population” and noted the cumulative COVID-19 infection rate was just 2.6% for dentists and 3.9% for dental hygienists, in November 2020 and October 2020, respectively. And while data collection ended last summer, the letter also pointed out that vaccination rates in dentistry have also been exceptionally high, and shared that as of June 2021, at least 89.8% of dentists had been fully vaccinated and at least 73.7% of dental hygienists were fully vaccinated as of August 2021.

“We strongly support the Centers for Disease Control and Prevention’s recommendations for the public to be vaccinated against COVID-19, including every member of the dental team,” Drs. Sabates and Cohlmia wrote. “Our concern with a vaccination and testing mandate is that it could exacerbate dental team shortages and, as a result, impede access to essential health care — even in parts of the country where infection rates are decelerating.”

“Compared to before the pandemic, dentists are facing major challenges in recruiting dental team members,” they wrote. “The vast majority of [dentists who own their practices] who are recruiting team members report being ‘extremely’ or ‘very’ challenged to fill vacancies for dental hygienists, dental assistants and administrative staff. Over 40% of dentists report that staffing shortages are limiting their ability to see more patients.”

“[R]equiring practice owners to institute a mandatory vaccination and testing policy will have little impact on the safety of dental office workers and the patients they serve,” the letter concluded. “Infection rates in dentistry are already low and vaccination rates are already high. However, it could have the unintended effect of exacerbating dental team shortages and impeding access to essential health care.”