Nobody wants to receive that phone call from public health. You know the one where they’re requesting an immediate inspection of your dental practice because of a potential infection control lapse.
Yet across Canada, dental offices continue to face closures and public health orders due to preventable IPAC failures. In Ontario alone, dozens of practices have been publicly named for violations in recent years. The consequences extend far beyond temporary closures: mandatory patient notifications, reputation damage, and in some cases, legal action.
Here’s what makes these situations particularly frustrating: most violations stem from the same handful of issues. We’ve analyzed public health inspection reports and worked with dental practices across Canada to identify patterns in what triggers compliance failures. For a comprehensive overview of proactive infection prevention strategies, consider reviewing our Dental Office IPAC Services to ensure full compliance with RCDSO and PIDAC standards.
This article breaks down the five most common IPAC failures inspectors find during dental office inspections. More importantly, we’ll show you how to prevent them before they become problems for your practice.
What Triggers a Dental Office IPAC Inspection?
Public health inspections don’t happen on a routine schedule. Three specific situations typically trigger an inspection of your practice.
First, patient complaints. When someone files a concern about infection control practices they witnessed during their visit, public health is required to investigate. Second, reportable disease investigations. If a patient develops hepatitis B, hepatitis C, or HIV, and recent dental work is identified, inspectors will assess whether transmission could have occurred at your office.
Third, and less commonly, surveillance activities follow known outbreaks in other facilities.
Inspectors arrive with authority under the Health Protection and Promotion Act. They’ll evaluate whether your practice complies with RCDSO guidelines, PIDAC best practices, and manufacturer instructions for your equipment. The inspection covers three main areas: documentation review, physical assessment of your reprocessing space, and direct observation of staff practices.
What Happens If Violations Are Found?
Inspectors categorize violations by risk level.
High-risk findings result in immediate practice closure until you demonstrate corrective action. Medium-risk violations give you a timeline to achieve compliance—typically 24 to 72 hours. Low-risk issues fall into the “inform and educate” category, though they’ll still be documented in the public report.
Orders can be issued orally for immediate concerns or in writing for documented action plans. Either way, both the initial inspection findings and your final compliance report become public records. They’re published online with your practice name and address attached.
Some practices have faced fines. Others have dealt with court orders. In extreme cases, clinic directors and owners have been held personally liable under the Act. If your office has recently undergone an inspection or received a compliance notice, our General IPAC Consulting service provides immediate corrective support and documentation review.
5 Critical IPAC Failures That Lead to Practice Closures
Failure #1: Missing or Incomplete Sterilization Records
This is the single most common violation found during inspections.
Inspectors need proof that your instruments were properly sterilized. Without complete documentation, there’s no way to verify that sterilization occurred at all, even if you know it did. The absence of records creates an immediate compliance gap that often triggers additional scrutiny of your entire IPAC program.
What makes this violation so prevalent? Many practices use manual log systems that are prone to gaps. Staff might skip entries during busy periods. Paper logs get misplaced. Someone forgot to document the spore test that was actually performed.
Inspectors will ask to see specific records: complete autoclave cycle logs showing temperature, time, and pressure for each run. Daily biological indicator testing results with corresponding control runs. Chemical indicator documentation, both internal and external. Maintenance logs for all sterilization equipment. And they want these records easily retrievable for any date they choose.
The fix requires system-level thinking rather than just asking staff to “be more careful.” Consider implementing digital sterilization tracking that automatically captures cycle data. Create standardized templates that make documentation faster and more consistent. Assign one team member as the designated records keeper who verifies completeness weekly.
Infection Shield’s IPAC Education Programs include documentation management modules that help streamline sterilization recordkeeping and inspection readiness.
Most importantly, conduct monthly audits of your own documentation. Don’t wait for an inspector to discover gaps. Keep a minimum of three years of records on-site and readily accessible.
Failure #2: Contaminated “Clean” Zones and Workflow Violations
Walk into your reprocessing area right now. Can you clearly identify where the dirty zone ends and the clean zone begins?
If the answer is “not really,” you’re at risk for this violation. Proper instrument reprocessing requires a one-way workflow: from soiled instrument reception through cleaning, then packaging, sterilization, and finally sterile storage. Instruments should never flow backward. Clean items should never occupy the same space as contaminated ones.
Inspectors consistently find practices where this separation doesn’t exist. Dirty and clean instruments sit on the same counter. Staff move back and forth between zones without changing gloves. The ultrasonic cleaner sits right next to the packaging station with no barrier between them.
This happens most often in practices with limited space. When your reprocessing area is essentially one long counter, maintaining proper zones becomes challenging. Staff take shortcuts during busy periods, placing a “just cleaned” instrument on a surface that had soiled instruments minutes earlier.
Physical space design matters here. Inspectors look for clear separation between your zones. This can be actual walls or partitions, or in smaller spaces, adequate spatial distance with clear visual markers. They want to see that instruments flow in one direction only—there’s no backtracking to earlier zones.
Fixing this violation might require redesigning your reprocessing area. Install physical barriers if your budget allows. At a minimum, use color-coding and clear labels to designate zones. Create a visual workflow map that staff can reference. Then observe your team in action to ensure they’re following the designated flow, even during busy periods.
If your reprocessing layout needs redesigning, our Construction & Renovation IPAC Consulting ensures new or renovated clinical spaces meet proper zoning and workflow requirements.
Failure #3: Wet Instruments Placed in Sterilization Pouches
Here’s a violation that seems minor but carries major implications.
Packaging wet instruments doesn’t just violate protocol; it can completely compromise the sterilization process. Moisture interferes with steam penetration and creates an environment where bacteria can survive the sterilization cycle. It also increases the risk of pouch tears and contamination during the sterilization process.
Why does this keep happening? Time pressure is the main culprit. Between patients, staff feel rushed to turn instruments around quickly. An instrument gets rinsed, briefly shaken off, and immediately packaged. Or the ultrasonic cleaner runs, items get a quick rinse, and staff assume that’s “dry enough.”
It’s not.
Inspectors will check your drying procedures. They want to see that the instruments are thoroughly dried before packaging. This means either adequate air-drying time (minimum 10-15 minutes) or the use of forced-air medical dryers. They’ll ask staff about the drying protocol and observe whether it’s actually being followed.
The solution requires both equipment and time allocation. Invest in a quality forced-air dryer designed for dental instruments. Build drying time into your reprocessing workflow, factor it into your scheduling so staff aren’t pressured to skip this step. Use lint-free absorbent cloths for any manual drying needed. Learn how our Dental Sterilization Process Audits can identify weak points in drying and packaging workflows to prevent recurring compliance issues.
Train your team on why this matters. When staff understand that wet instruments can harbor bacteria even after sterilization, compliance improves dramatically.
Failure #4: Missing Daily Spore Tests and Sterilizer Failures
Every sterilizer cycle should be monitored. Every single one.
Chemical indicators confirm that packages were exposed to heat. Biological indicators—spore tests—confirm that the sterilization conditions were sufficient to actually kill microorganisms. Without daily spore testing, you have no proof your sterilizer is doing its job.
Yet inspectors routinely find practices with gaps in spore testing. Some skip tests on “slow days” to save money. Others forget during busy periods. Many don’t understand that control runs are required with every spore test to verify the test system itself is working properly.
Here’s what makes this violation particularly serious: if you haven’t been testing regularly and your sterilizer has been malfunctioning, you may have been using improperly sterilized instruments for weeks or months without knowing it. That triggers mandatory patient notification requirements and potential disease testing for everyone treated during that period.
Inspectors will review your spore test logs. They want to see daily testing with results documented. They’ll check that you’re running control spore tests alongside your test spore tests. They’ll look for documentation of your response to any failed tests—equipment taken offline, instruments recalled, and corrective action completed before restarting.
Make daily spore testing your first task every morning, without exception. Consider mail-in systems or rapid readout tests that provide results within hours. Create a written protocol for sterilizer failures that clearly outlines the steps to take. Schedule annual preventive maintenance for all sterilizers and keep those records with your other documentation.
Our IPAC Training Workshops teach dental teams to perform and document spore tests effectively, minimizing risk during public health reviews.
Failure #5: Poor Hand Hygiene and PPE Practices
This violation is almost always caught through direct observation.
Inspectors watch staff moving through your practice. They notice when someone walks down the hallway wearing gloves they just used in the operatory. They see staff touching door handles, phones, or computer keyboards with contaminated gloves. They observe whether hand hygiene is actually performed at the proper moments.
These practices spread contamination throughout your office. A staff member treats a patient, keeps their gloves on, walks to the front desk to check the schedule, then returns to the operatory. Everything they touched is now contaminated.
Why does this happen? Habit and convenience, mainly. Changing gloves between tasks feels inefficient. Hand hygiene stations might not be conveniently located. Staff forget in the flow of a busy day. Or they genuinely don’t understand which moments require hand hygiene and when gloves must be changed.
Inspectors look for gloves being changed between patients and between different tasks. They want to see staff removing gloves before leaving clinical areas (except when transporting soiled instruments directly to reprocessing). They check whether hand hygiene is performed at critical moments: before patient contact, before aseptic procedures, after body fluid exposure risk, after patient contact, and after contact with patient surroundings.
Fix this by making hand hygiene unavoidable. Install alcohol-based hand rub dispensers at every room exit. Post visual reminders about glove changes. Provide adequate PPE supplies in all sizes so staff never face the temptation to keep gloves on “just for a minute” because finding new ones is inconvenient.
Most importantly, observe your team regularly. Don’t assume compliance because you’ve trained staff. Watch how practices actually flow during busy periods when old habits tend to resurface.
Review our IPAC Long-Term Care Resources, which provide proven approaches to improving PPE compliance and hygiene culture across healthcare teams.
Beyond the Top 5: Other Common Violations
Inspectors consistently identify several additional issues beyond these five major failures:
Expired products sitting in drawers, such as anesthetic carpules, disinfectants, sterile water bottles, or hand sanitizers past their expiration dates. Dental waterline maintenance is neglected, with no testing or treatment protocols in place. Single-use items are being reused, particularly evacuation tips or saliva ejectors. Cleaning equipment, such as ultrasonic units not properly emptied, cleaned, and disinfected between uses.
Missing or outdated IPAC policy manuals that don’t reflect current practices or recent guideline updates. No documented staff training records, making it impossible to verify that your team has received the required annual education. Improper sharps disposal, including overfilled containers or sharps bins without proper closing mechanisms.
Each of these violations can compound the seriousness of an inspection, particularly when found alongside the five major failures outlined above.
How to Prepare Your Practice for Compliance
Waiting for an inspection notice isn’t a strategy. Proactive practices conduct regular self-audits using the same checklists public health inspectors use. Public Health Ontario provides comprehensive IPAC assessment tools specifically designed for dental settings. Use them monthly to catch issues before they become violations.
You can download our Free IPAC Self-Audit Checklist from our Resource Hub to align your internal reviews with Public Health Ontario standards.
Staff training deserves significant investment. Annual formal training is mandatory under RCDSO guidelines, but effective programs go beyond minimum requirements. Focus intensive training on your reprocessing staff, as they handle the most critical infection control procedures. Document every training session with certificates and attendance records. External IPAC consultants can provide specialized training that elevates your entire program beyond basic compliance.
Documentation systems need upgrading in many practices. Digital sterilization tracking captures more data with less staff effort. Cloud-based storage with automatic backups ensures records are never lost. These systems generate reports that inspectors can review immediately rather than watching staff flip through months of paper logs.
Consider creating an “inspection-ready” binder that contains everything inspectors typically request. Include your complete sterilization records for the past three years, all spore test results with control runs, equipment maintenance logs, and manufacturer instructions for every piece of equipment you use. Add your current IPAC policy and procedure manual, staff training records, water quality testing, if applicable, Safety Data Sheets for all chemicals, and preventive maintenance schedules.
When an inspector arrives, you should be able to hand them this binder within minutes rather than scrambling to locate documents.
When to Call in Professional Help
Some situations require expert assessment before problems escalate.
Consider working with an IPAC consultant if your self-audit reveals significant gaps, if you’re preparing for a known upcoming inspection, or if you’ve already received violation notices. Failed self-audits indicate systemic issues that might not be obvious from inside your practice. A third-party assessment brings a fresh perspective.
Professional consultants provide comprehensive office assessments that mirror public health inspection processes. They audit your sterilization center in detail, observe staff practices to identify compliance gaps, and deliver specific training tailored to your practice’s needs. This creates an opportunity to fix problems before public health finds them.
The value of third-party gap analysis extends beyond avoiding violations. External experts help you build robust systems that make compliance easier long-term, reducing the ongoing burden on staff while improving patient safety outcomes.
If you’re facing urgent inspection timelines, contact our Toronto IPAC Consulting Team for a same-day assessment and customized remediation plan.
Protecting Your Practice and Your Patients
These five failures appear repeatedly in inspection reports because they’re rooted in common operational challenges every dental practice faces: time pressure, limited space, staff turnover, and the complexity of maintaining multiple detailed protocols simultaneously.
They’re also entirely preventable.
IPAC compliance isn’t primarily about avoiding inspections or public health orders. It’s about ensuring that every patient who walks into your practice can trust they’re receiving care in an environment where their safety is prioritized above convenience or efficiency.
Start with one improvement area, whichever failure represents your biggest current risk. Build robust systems around that issue, then move to the next. Systematic improvement creates sustainable compliance that doesn’t require constant vigilance or depend on individual staff members never making mistakes.
Your practice, your reputation, and most importantly, your patients deserve nothing less than comprehensive infection prevention and control. Explore our IPAC Blog for more insights on preventing compliance lapses and maintaining patient safety standards in Canadian dental practices.
Frequently Asked Questions
How often should dental offices perform spore testing?
Daily spore testing is the standard requirement for practices using their sterilizers every day. Every spore test must include a control run to verify that the test system itself is functioning properly. Some practices ask whether they can skip testing on days they don’t use the sterilizer; that’s acceptable, but the first cycle when you resume must include a spore test before instruments from that cycle are used on patients.
What happens if a dental office fails an IPAC inspection?
The outcome depends on violation severity. High-risk findings result in immediate closure until corrective action is demonstrated and verified. Medium-risk violations typically require compliance within 24-72 hours with follow-up verification. All findings become public records published online with your practice information. Serious violations may trigger mandatory patient notification requirements, potential fines, or legal action under the Health Protection and Promotion Act.
Do dental practices need separate rooms for instrument reprocessing?
Not necessarily, though dedicated space is ideal. What’s required is a clear separation between dirty and clean zones within your reprocessing area. This can be achieved through physical barriers, adequate spatial separation, or well-designed workflow systems that prevent contamination of clean areas. Small practices with limited space can still comply if they establish proper zones and ensure staff follow one-way workflow protocols consistently.
How long must dental offices keep sterilization records?
Keep a minimum of three years of complete sterilization documentation on-site and readily accessible. This includes autoclave cycle logs, spore test results, chemical indicator documentation, maintenance records, and any corrective action documentation. Some practices retain records longer for additional protection. Digital systems make longer retention periods more practical than paper-based systems.
Can dental offices reopen immediately after fixing IPAC violations?
Reopening requires public health verification that corrections are complete and effective. For high-risk violations, you must demonstrate corrective action, provide evidence of compliance, and receive clearance from the inspector before resuming patient care. Medium-risk violations follow a similar process with shorter timelines. Low-risk issues may only require documentation of corrections. The reopening process varies by violation type and local health unit protocols.