AGD filed a comment with the Occupational Safety and Health Administration (OSHA) on its interim final Emergency Temporary Standard (ETS), Occupational Exposure to COVID-19 in Healthcare Settings. This is the second AGD comment to OSHA on its ETS. OSHA invited comments on whether the interim final rule should become a permanent rule. AGD does not support that action and recommends withdrawing the interim rule, as there was not a scientific foundation to support the rule going into final status. Absent that action, AGD strongly recommended against removing the exemption for ambulatory surgical centers such as dentists’ offices.

Early in the pandemic, the dental community instituted strict procedures using a hierarchy of controls to keep COVID-19-symptomatic or COVID-19-positive patients out of their practices. Dental offices have demonstrated an exceptional infection control safety record. AGD is not aware of any peer-reviewed journal articles that document the spread of COVID-19 in dental offices. 

The comment states that AGD does not support a federal approach that would allow for a variation of the SARS-CoV-2 virus to be considered a distinct genetic drift and thereby designated a new novel coronavirus. AGD additionally advocated for long-term data collection on all therapies associated with COVID-19 and added that federal agencies should update that information on a weekly basis to aid in informed decision-making for clinicians and patients.