The Growing National Conversation 

Several outbreaks of Mycobacterium abscessus have been reported over the past decade. The worst, and best known, occurred in California. Of 71 confirmed cases, 70 were hospitalized for a mean 8.5 days and required surgical intervention. All cases were in children who had undergone pulpotomy procedures at the same clinic. This and other headline grabbing cases have prompted regulatory authorities to begin to act, and the trend toward regulating water lines matches a growing emphasis on preventing health care-associated infections in all settings.  

In Georgia, the Board of Dentistry already has existing rules governing infection control. One rule (Ga. Comp. R. & Regs. r.  150-8-.01(a)) directs dentists to follow Centers for Disease Control and Prevention (CDC) guidelines, particularly as relates to bloodborne pathogens. Another rule requires continuing education on infection control with a special emphasis on dental unit water lines. The Board’s new rule adds an infection control requirement that mirrors existing CDC guidance.  

What will the new rule require? 

Given 2 existing regulatory models in West Coast states, California and Washington, the Board selected Washington’s as a base, and they chose to focus on water line testing. Unlike California’s more burdensome rule, Washington’s rule largely restates long time recommendations broadcast by public health authorities. The new Georgia rule would require: 

• Offices to use water meeting EPA drinking water standards (≤ 500 CFUs/mL) 

• Offices to follow manufacturers’ instructions for use when testing water quality, to test water quality at least quarterly, and to test water quality within 30 days of plumbing modifications 

• To take remedial action if an unacceptable level of colony-forming units (CFUs) is identified 

• To keep a log for a period of at least 5-years recording dates, the person conducting the tests, and reports from an independent testing entity 

The full text of the proposed rule can be found below. 

How Will This New Rule Affect Georgia Dental Practices? 

The rule is unlikely to have a major impact on most dental practices. Many practices are already testing water quality and addressing issues as they arise. They may have to adapt existing practices to fit the new rule, but the rule should be easy an easy adjustment. 

Estimating the cost of the new rule depends on what offices are already doing. Even if a practice were conducting no water quality testing, the expense of adding the testing is minimal. When Washington implemented their law, analysts at their department of health estimated that the cost of quarterly water testing for 4 operatories would range between $472.88 and $1,199.36 annually. They estimated the cost by adding the cost of tests to a range of potential labor costs. Most of the cost variation revolves around who does the testing and logging. 

A back of the envelope calculation for Georgia can easily be done using the same method. Assuming a median hygienist wage of $35 per hour, 4 operatories, 15 minutes of staff time per operatory tested, and a test cost of $409 for 16 vials, then a practice would spend an additional $549 for testing and maintaining the required log. Some additional cost may also be incurred if the office is then required to shock their lines or replace equipment, but the most likely scenarios are still relatively inexpensive. 

Georgia Dental Association is Helping Dentists Prepare

One of the benefits of GDA membership is access to GDA Plus + Supplies. GDA’s supply company provides dental supplies to member dentists, often at lower prices than other major supply companies. Water testing and infection prevention supplies are among the many items available for order today.  

To get more involved in advocating for dentistry in the state of Georgia, consider attending LAW Day, signing up as a contact dentist, or donating to GDAPAC.