As workplaces, technology, and safety controls change, OSHA periodically reviews its standards to determine whether existing requirements should be updated, clarified, or removed. OSHA is currently considering a series of deregulatory actions intended to modernize workplace safety standards, eliminate requirements the agency considers outdated or duplicative, and provide employers with greater flexibility in complying with certain requirements.
Respiratory Protection Standard – Medical Evaluations
Currently, employers generally must provide a medical evaluation before an employee may use a respirator. OSHA has proposed removing certain medical evaluation requirements for employees using filtering facepiece respirators, such as N95s, and loose-fitting powered air-purifying respirators (PAPRs).
If finalized, this could affect respiratory protection programs in some dental settings. However, the proposal does not change current requirements. Employers must continue complying with existing medical evaluation requirements while the rulemaking process is underway.
OSHA Is Reconsidering How the General Duty Clause May Be Applied
Section 5(a)(1) of the Occupational Safety and Health Act requires employers to provide a workplace free from recognized serious hazards when no specific OSHA standard addresses the hazard.
OSHA has proposed clarifying that the General Duty Clause would not be used to enforce certain hazards considered inherent and inseparable from the core nature of a professional activity or performance. This would not eliminate employers’ responsibility to address preventable workplace hazards or comply with existing OSHA standards.
Proposed Chemical Standard Changes
Additional proposals would revise respiratory protection provisions in several substance-specific standards, including formaldehyde and ethylene oxide—chemicals that may be encountered in laboratory, pathology, or sterilization environments. Employers should continue to maintain accurate chemical inventories, Safety Data Sheets, exposure assessments, and Hazard Communication Programs.
Proposed Does Not Mean Final
A proposed OSHA rule is part of the federal rulemaking process. OSHA publishes the proposal, accepts public input, evaluates comments and other information, and may ultimately issue a final rule. The final requirement may differ from the original proposal—or the proposal may not become a final rule at all.
OSHA’s informal public hearings on several of these deregulatory proposals were conducted in late August 2026. Until OSHA finalizes any changes, dental employers should continue to follow the standards currently in effect, including requirements for training, medical evaluations, fit testing, exposure assessments, and documentation.
In the meantime, the proposed changes provide a good opportunity to review existing safety programs. Confirm that written policies reflect current requirements, employees are receiving required training, established procedures are being followed, and the Hazard Communication Program accurately reflects the chemicals present in the workplace.
OSHA’s deregulatory efforts may eventually modify or simplify certain employer obligations. For now, however, employers should monitor the rulemaking process and wait for final action before making compliance changes.