Dental Infection Control CQC Guide: What Inspectors Check in Dental Practices

Liam

2 days ago

5 min read

This guide to dental infection control CQC expectations explains what inspectors look for, drawing on my 12+ years as a CQC inspector. Most practices work hard on cleanliness. The challenge is showing it, with a clear policy, a named lead, regular audits and complete equipment records.

Dental infection control CQC guide: what inspectors check in dental practices — Infection prevention and control in dental practices: what CQC inspectors check under HTM 01-05 and Regulations 12 and 15.

Key takeaways

• CQC assesses infection prevention and control (IPC) in dental practices against Regulation 12 (safe care and treatment) and Regulation 15 (premises and equipment).

• CQC uses the Health and Social Care Act 2008 Code of Practice on IPC when assessing whether you meet the regulations. Appendix B covers primary care dental practices.

• HTM 01-05 says practices should audit decontamination at least every six months. It strongly recommends the Infection Prevention Society (IPS) audit tool.

• Decontamination equipment needs validation at installation and annually. Sterilisers also need a written scheme of examination, with no more than 14 months between inspections.

• Keep steriliser cycle records and audits for at least two years.

What does CQC look at when assessing dental infection control?

CQC's Dental mythbuster 38 says inspectors look at Regulation 12 and Regulation 15. Regulation 12(2)(h) requires providers to be "assessing the risk of, and preventing, detecting and controlling the spread of, infections, including those that are health care associated". Regulation 15 requires premises and equipment to be clean and hygiene standards to be appropriate for how they are used.

The mythbuster says CQC will assess how you:

maintain standards of cleanliness and hygiene
have reliable systems to prevent and protect people from a healthcare-associated infection
maintain and use facilities and premises in a way that keeps people safe
manage waste and clinical specimens to keep people safe

How does the Code of Practice on IPC apply to dentists?

The Code of Practice was refreshed on 13 December 2022 and applies to providers in England, including primary dental care. It sets out 10 criteria against which a registered provider will be judged.

The Code itself is not mandatory. However, CQC must take it into account when making registration decisions, and providers must have regard to it. You can meet the regulations in a different way, but you must be able to show it is equivalent or better.

Appendix B gives examples for dental practices. It states that the Code "has taken due note of HTM 01-05 and does not impose any additional burdens on decontamination". It also expects a designated IPC person, who could be the registered provider, the registered manager or another member of staff.

What does HTM 01-05 require?

HTM 01-05 (2013 edition) is the national guidance on decontamination in primary care dental practices. It describes two levels.

What is the difference between essential quality requirements and best practice?

Essential quality requirements are the level every practice should meet. Instruments should be free of visible contamination when inspected and reprocessed using a validated cycle that includes cleaning and a validated steam steriliser. You should also have a plan for moving towards best practice.

Best practice adds a validated washer-disinfector, decontamination in a separate room or rooms away from the treatment area, and instrument storage that is separate from the clinical area.

How long can instruments be stored?

Wrapped instruments: up to one year.
Unwrapped instruments in a clinical area: maximum one day.
Unwrapped instruments in a non-clinical area: maximum one week.

How often should you audit decontamination?

HTM 01-05 says that, at a minimum, practices should audit their decontamination processes every six months, with a review depending on the results. Audits should be available to regulators, stored for at least two years and not removed from the premises or destroyed.

What do inspectors check on decontamination equipment?

Dental mythbuster 12 covers validation. Inspectors look for:

validation of new decontamination equipment at installation and annually after that
periodic tests for sterilisers, ultrasonic baths and washer-disinfectors, in line with the manufacturer's instructions or HTM 01-05
a record of every sterilisation cycle, showing the steriliser is working within validated parameters
records kept for at least two years
a written scheme of examination for each steriliser, with current certification and no more than 14 months between safety inspections

What if you do not have a separate decontamination room?

Dental mythbuster 18 accepts that building constraints can make a separate room impossible. If you reprocess instruments in the treatment room, CQC expects you to keep the reprocessing area as far from the dental chair as possible. Do not wash instruments by hand or use an uncovered ultrasonic cleaner while a patient is in the room. Keep a dirty-to-clean workflow throughout.

What other IPC evidence will inspectors ask for?

Mythbuster 38 sets out the general requirements:

IPC policy: relevant to your practice, accessible to all staff and updated regularly. It should cover higher-risk procedures, training, PPE and responsibilities for cleaning clinical equipment.
IPC lead: a named person with overall responsibility and the authority to make changes.
Audit programme: showing issues found and how you addressed them.
Cleaning schedule: including high-touch items such as keyboards, telephones, door handles and light switches.
Staff health: access to occupational health and immunisation in line with the Green Book.
Waste: lidded, foot-operated bins in clinical areas, and bags no more than two-thirds full, tied, labelled and stored securely.
Hand hygiene: a written policy, and no bars of soap, nail brushes or alcohol-impregnated wipes for cleaning hands.

What practical steps should you take before your next inspection?

Confirm your IPC lead in writing and make sure the team knows who it is.
Review your IPC policy against mythbuster 38 and add a review date.
Complete the IPS audit, record an action plan and check the date of your next audit is no more than six months away.
Check equipment certificates, including annual validation and the steriliser written scheme of examination.
Sample your cycle records to check every cycle is logged and within parameters.
Spot-check instrument storage against the one-year, one-day and one-week limits.
Walk the decontamination route and confirm it flows from dirty to clean.
Check training and immunisation records for everyone involved in decontamination.
Update your best practice plan so it shows how you will improve.

Frequently asked questions

How often should a dental practice audit infection control?

HTM 01-05 says at least every six months. It strongly recommends the IPS/DH audit tool.

Does CQC require a separate decontamination room?

No. HTM 01-05 treats a separate room as best practice. Mythbuster 18 explains how to reduce risk if you reprocess in the treatment room.

How long should steriliser records be kept?

Mythbuster 12 says records need to be kept for a minimum of two years. HTM 01-05 also says audits should be kept for at least two years.

Is the Code of Practice on IPC mandatory?

No, but providers must have regard to it, and CQC must take it into account. You need to show your approach is equivalent or better.

How I can help with dental infection control and CQC compliance

As a former CQC inspector with 12+ years of experience, I offer compliance support and mock inspections that include hygiene and infection control. I can review your IPC policy, audits, validation records and decontamination process, and talk to your team about how they apply them.

Virtual Compliance Review (£499): a remote review of key policies, audits and compliance evidence, with a prioritised action plan.
Full Comprehensive Mock Inspection (£1,799): an on-site assessment with evidence sampling, observations, staff interviews and a detailed improvement plan.

Find out more at www.cqcconsultancy.net.

Email hello@cqcconsultancy.net to discuss your practice.