We’ve Completed 195 Dental Audits in the Past Year: The 3 IPAC Gaps We See Again and Again

In the past year, IPAC Consulting completed 195 dental audits across a wide range of dental practices. While each clinic was different, our consultants noticed something important: the same types of IPAC gaps kept showing up. These gaps were not usually because teams did not care or because staff were not working hard. In many cases, the opposite was true. Teams were busy, engaged, and doing their best to keep up with patient care, documentation, reprocessing, and daily clinic demands. The issue was that many clinics were relying on habits, verbal training, and scattered documentation instead of clear, repeatable systems—and that is exactly where IPAC risk often starts. After reviewing audit trends across these dental practices, three recurring themes stood out.

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Reprocessing Workflows Were Not Always Clearly Protected From Cross-Contamination

Reprocessing is one of the highest-risk areas in a dental clinic because it depends on the right steps happening in the right order, every time. Even when staff understand the basics, the physical setup of the space can make compliance easier or harder. Across audits, our consultants often observed that clinics had a designated reprocessing area, but the workflow was not always clearly protected from cross-contamination.

Common issues included drying and packaging taking place too close to the manual cleaning area, an unclear separation between dirty and clean activities, and staff completing the right steps but not always in a consistent order. Furthermore, we frequently saw contaminated instruments being transported without covered containers, as well as clean or sterile supplies being moved without enough protection.

These are not always training problems; often, they are workflow problems. A dental team can have knowledgeable staff and still run into risk if the setup of the clinic does not support the correct process. When dirty instruments, clean supplies, drying areas, and packaging areas overlap, staff are forced to rely on memory and caution instead of a system that naturally guides the right behaviour.

How to Fix It:
To address this, walk through the reprocessing process from beginning to end. Follow the path of a contaminated instrument from the operatory to decontamination, cleaning, drying, packaging, sterilization, storage, and its ultimate return to the treatment room. As you do, ask yourself the following critical questions:

• Is there a clear one-way flow from dirty to clean?
• Are drying and packaging areas protected from splash and spray?
• Are contaminated instruments transported in covered, puncture-resistant containers?
• Are clean and sterile items protected when moved back to operatories?
• Could a new team member understand the workflow without relying only on verbal instructions?

When the answer is unclear, the fix may be as simple as adding signage, adjusting where drying occurs, using covered transport containers, adding a physical barrier, or standardizing the process across all staff. Small workflow changes can make a major difference because they reduce the need for staff to “remember” every step perfectly during a busy clinical day.

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2. Documentation Was Happening, but It Was Not Always Inspection-Ready

One of the biggest themes we see in dental audits is not that documentation is completely missing. More often, the issue is that documentation exists in too many places, is not consistently completed, or cannot be found quickly when needed. That matters immensely. During an inspection, it is not enough to say, “We do that”—your team needs to be able to show it.

Common documentation gaps typically span across sterilizer records, ultrasonic cleaner testing logs, preventative maintenance documentation, waterline testing results, and staff training records. We also frequently find issues with package labelling, policy review dates, equipment documentation, Manufacturer’s Instructions for Use (MIFUs), and Safety Data Sheets (SDS).

In other words, the work may be happening, but the evidence is not always easy to prove. This can create unnecessary stress for clinics. A process may be completed correctly most of the time, but if the documentation is incomplete, inconsistent, or scattered across binders, email folders, shared drives, paper logs, and individual staff knowledge, the clinic may appear less prepared than it actually is. Inspection readiness is not just about having the right documents; it is about knowing where they are, keeping them current, and being able to access them quickly and confidently.

How to Fix It:
Create one clear system for compliance documentation. Whether your clinic uses a digital platform, a structured binder system, or a combination of both, your staff should know exactly where to find the documents that support your IPAC program. At a minimum, clinics should be able to quickly access:

• Sterilizer logs and ultrasonic testing records
• Waterline testing results and preventative maintenance records
• Staff training documentation and current IPAC policies and procedures
• MIFUs for equipment/devices and SDS sheets for products used in the clinic
• Audit reports and action plans

The goal is not just to have the information; the goal is to retrieve it quickly when asked. If Public Health, the College, or another inspector asks for documentation, your team should not have to scramble. A strong documentation system allows your clinic to respond with confidence.

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3. MIFUs Were Not Always Easy to Access or Built Into Daily Practice

Manufacturer’s Instructions for Use, often called MIFUs, are essential in dental IPAC. They tell your team how equipment, devices, instruments, products, sterilizers, ultrasonic cleaners, biological indicators, handpieces, waterline products, and other items are supposed to be used, cleaned, disinfected, sterilized, maintained, stored, or replaced. The challenge is that MIFUs are often treated as background documents instead of active tools. A clinic may technically have the MIFU somewhere, but if staff cannot find it quickly, do not know when to reference it, or are relying on memory instead, the clinic can still be at risk.

Across audits, MIFU-related issues commonly appeared in areas such as instrument disassembly, ultrasonic cleaner use, biological indicators, waterline products, handpiece reprocessing, and reusable air/water syringe tips. We also see gaps regarding single-use versus reusable devices, equipment maintenance, and sterilizer operation.

This is where many well-intentioned teams can run into trouble. Staff may be following the process they were taught years ago, or the process that has always been used in the clinic, but that process may not match the current manufacturer’s instructions for that specific device or product. Even the strongest team still needs access to the right, up-to-date information.

How to Fix It:
Build a clinic-specific MIFU library and make it easy for staff to use. This library should reflect the actual equipment, devices, and products being used in your clinic, and it should be reviewed whenever new products are purchased, equipment changes, or procedures are updated. A strong MIFU system helps staff answer practical daily questions quickly, such as:

• Can this item be reprocessed, or is it single-use?
• Does it need to be disassembled?
• What cleaning method is required and what sterilization cycle applies?
• What maintenance is required, and how often should testing or replacement occur?

When MIFUs are easy to access, they become an integrated part of the daily workflow instead of a last-minute scramble during an audit or inspection.