A Local Reminder: Why Infection-Control Testing & Documentation Matter
A recent Colorado dental license suspension offers a practical reminder that strong systems, verified results, consistent training, and reliable documentation protect patients and practices.
Infection-Control Concerns Can Happen Anywhere
Infection-control failures can feel like distant events that happen somewhere else. A recent enforcement action in Monument, Colorado, is a reminder that compliance concerns can arise anywhere, including within our own small-town community.
According to a September 24, 2026 report from KRDO13 Investigates, the Colorado Dental Board suspended the license of a local dentist after determining that emergency action was necessary to protect public health, safety, and welfare. The report described allegations involving patient care, infection control, and services performed in a medical spa setting. The dentist acknowledged several deficiencies while maintaining that patients were safe.
This article is not intended to judge an individual practice or predict the final outcome of an ongoing regulatory matter. A summary suspension is an emergency regulatory action, and the case may continue through the appropriate administrative process. Instead, the event offers every dental team a timely opportunity to review the systems that support safe, consistent care.
What the Report Highlights
KRDO reported that the investigation began with a patient complaint and was followed by an unannounced inspection. The Board’s order identified nine infection-control deficiencies. Among the reported concerns were failure to conduct biological spore testing, failure to maintain a written policy for responding to a failed spore test, and failure to test dental waterlines.
That distinction matters. The reported concern was not simply whether a practice had a treatment product, sterilizer, or general protocol in place. It was whether critical processes were being tested and verified. Infection prevention depends on more than good intentions or equipment that appears to be working. It depends on repeatable procedures that are performed, measured, documented, and corrected when results fall outside expectations.
Treatment manages risk. Testing verifies performance.
Board Identified Deficiencies
Failure to conduct spore testing for instrument sterilization and failure to maintain a written policy addressing failed spore tests;
Improper instrument-sterilization practices;
Failure to test dental waterlines;
Failure to provide employees with annual training on OSHA and CDC guidelines;
No infectious-waste contract;
No records of tuberculosis testing for employees;
No written bloodborne-pathogen exposure plan or established referral clinic;
Failure to use antibacterial hand soap despite performing surgery; and
Failure to use sterile gloves.
Infection Control is a System,
Not a Single Task
A strong infection-prevention program connects written policies, trained personnel, reliable supplies, routine monitoring, and clear accountability. When one part is missing, the rest of the system becomes harder to verify.
Written Procedures: Staff should have clear, current instructions for instrument reprocessing, environmental cleaning, dental unit waterline management, exposure response, and other applicable tasks.
Defined Responsibility: Every recurring task should have an owner, a schedule, and a backup person.
Training and Observation: Team members need initial and recurring education, followed by direct observation to confirm that procedures are performed correctly.
Monitoring and Records: Logs, test results, maintenance records, and corrective actions provide evidence that the system is functioning.
Response Plans: A result outside the acceptable range should trigger a documented process for containment, correction, retesting, and return to service.
Dental Waterlines: Treatment is Not the Same as Verification
The reported failure to test dental waterlines deserves particular attention because waterline maintenance can easily become activity-focused. A team may faithfully add a treatment tablet, replace a cartridge, shock lines, or follow another maintenance protocol. Those steps are important, but the protocol itself does not reveal the microbial quality of the water delivered to the patient. The result does.
The CDC’s dental unit water quality guidance states that dental treatment water for nonsurgical procedures should meet drinking-water standards of no more than 500 colony-forming units per milliliter (CFU/mL) of heterotrophic water bacteria. The CDC also states that dental unit waterlines should be treated regularly and that water quality must be monitored, or tested, routinely as recommended by the equipment manufacturer. Routine testing helps confirm that treatment is working, identify performance or maintenance problems, and document compliance. For surgical procedures, the CDC recommends sterile saline or sterile water delivered through an appropriate sterile device.
The practical takeaway is simple: practices may use different treatment products and maintenance approaches, but each approach is working toward the same outcome, water that meets the applicable quality benchmark. Testing turns that desired outcome into a measurable result.
A Dependable Waterline Quality System
Agenics Labs recommends organizing dental waterline management around five connected actions:
Treat: Use a compatible maintenance product or system exactly as directed by the dental unit and treatment product manufacturers.
Test: Verify output water at a routine frequency based on applicable requirements and manufacturer recommendations. The purpose is not simply to show that a protocol was followed, but to confirm that the protocol produced acceptable water-quality results.
Quarterly or monthly testing is a good cadence to start with.
Document: Record the dental unit, date, test method, result, reviewer, and any corrective action. Records should be organized and accessible before an inspection, audit, or patient concern occurs.
Respond: When a result exceeds the action level, follow the dental unit and treatment product manufacturers’ instructions, apply the practice’s written corrective-action protocol, and retest to verify that water quality has returned to the acceptable range.
Review: Look for patterns across operatories, products, staff practices, source water, and periods of stagnation. Trends can reveal vulnerabilities that a single result may not explain.
A note on testing methods: Different methods can serve different operational needs. The important point is to select an appropriate method, understand what the result means, keep the record, and act when the result requires attention. Learn More.
Sterilization Monitoring: Verification Matters Here, Too
The same principle applies to instrument sterilization. The CDC’s sterilization monitoring guidance recommends using mechanical, chemical, and biological monitoring together. Mechanical monitoring checks time, temperature, and pressure for every sterilizer load. Chemical indicators help confirm that the sterilizing agent reached the instruments inside each package. Biological monitoring, commonly called spore testing, directly assesses the sterilization process and should be performed at least weekly for each sterilizer.
Monitoring is useful only when the team knows how to respond. A written policy should identify who reviews results, what happens when an indicator suggests a problem, how potentially affected instruments are handled, when equipment is removed from service, how corrective action is documented, and what criteria must be met before the sterilizer returns to use. Manufacturer instructions and applicable requirements should remain central to that process.
A Practical, No-Blame Self-Audit
The lesson from an enforcement story should not be panic. It should be preparation. A short, structured review can help a practice identify small gaps before they become larger problems.
Confirm that infection-prevention policies reflect current guidance, applicable state requirements, manufacturer instructions, and the services the practice actually provides.
Review dental waterline treatment, testing, remediation, and retesting records by unit. Confirm that the records show results, not only that maintenance activities occurred.
Verify that each sterilizer has current maintenance records and complete mechanical, chemical, and biological monitoring documentation.
Review the written response procedure for a failed water test or positive spore test, and make sure team members can explain their roles.
Observe instrument transport, cleaning, packaging, sterilization, storage, and chairside handling from start to finish.
Confirm that single-use items are discarded after one patient and reusable devices are processed according to their instructions for use.
Check that new services have been evaluated for scope of practice, training, consent, medication handling, emergency readiness, and infection-control requirements.
Assign corrective actions to a specific owner with a due date, then verify completion.
Build a Culture That Makes the Right Action Easier
Most dental professionals want to provide safe, dependable care. The challenge is turning that commitment into systems that remain reliable on busy days, during staffing changes, and when new services are introduced. Practices are stronger when team members can report a missed step or unexpected result without hesitation, and when leaders respond by strengthening the process rather than assigning blame.
Routine audits, clear checklists, recurring training, and dependable testing all support that culture. They also make inspections less disruptive because records are maintained as part of normal operations rather than assembled only after a concern arises.
The Takeaway
Infection-control deficiencies can occur anywhere. That does not mean dental teams should operate from fear. It means every practice can benefit from pausing, reviewing its systems, and closing gaps before they affect patient care or practice operations.
For dental waterlines, the path forward is measurable: use an appropriate treatment protocol, test routinely, document the results, and respond promptly when a result is outside the acceptable range. Treatment is essential, but testing is what verifies that the water delivered at the chair meets the intended standard.
Agenics Labs supports dental teams with mail-in and in-office testing options, accessible result records, customer support, and data-informed guidance when results need attention. Practices can learn more about dental water testing solutions from Agenics Labs.