Audit-Ready Dentistry: AS 5369 by 2025

With AS 5369 and the December 2024 implementation guidance for Preventing and Controlling Infections in primary care now in effect, every dental practice has a clear path—and a firm deadline—to tidy reprocessing workflows, documentation, and competency records before 2025 compliance checks. Here’s a practical, business-focused story of how one small practice turned risk into readiness.

1) Introduction: The Compliance Wake-Up Call

“We’re a small team—do we really need enterprise-level documentation?” That was Mia, the owner of a four-chair suburban clinic, after reading the AS 5369 transition note and the new implementation guidance. The answer was immediate: yes. Effective infection prevention and control is central to high-quality care and a safe workplace, and audits would soon test whether her systems could prove it.

2) The Risk Reality: What Auditors Are Flagging

Common nonconformances

Instrument traceability gaps: trays not linked back to patients or loads.
Benchtop steriliser validation: overdue performance qualification, unclear maintenance logs.
Outdated infection control manuals: policies not reflecting AS 5369 and the Dec 2024 guidance.

Mia realized that “good practice” wasn’t enough—she needed evidence. Formal inclusion of dental practitioners as relevant health practitioners means the bar is explicit: you must adhere to prescribed infection control standards, demonstrate staff competency, and show a maintained dental unit waterline schedule.

3) The Plan: A 10-Day Internal Audit Sprint

Three moves to regain control

Map procedures to authoritative sources. Align each step with the Dental Board of Australia Infection Prevention and Control Guidelines and ADA resources, using the Dec 2024 primary care implementation guidance as the bridge.
Build a single source of truth. Centralize SOPs, logs, and competency records in one controlled manual—physical or digital—and archive the rest.
Prove load release. Confirm the release criteria: a complete cycle record plus a chemical indicator per load, documented and cross-referenced.

“Document your business or get out.” — the mantra Mia pinned above the sterilisation room. Clarity beats memory.

4) Reprocessing, Mapped and Measurable

From receive to release

Receiving and segregation: contaminated instruments logged at point of use.
Cleaning: mechanical/ultrasonic cleaning with visual checks and documented detergent concentrations.
Inspection and packaging: pouches labeled with date, load ID, and initials.
Sterilisation: load assembled with a chemical indicator; cycle record captured.
Release and storage: only released when both cycle record and indicator meet criteria; storage conditions recorded.

Traceability upgrade

Assign unique load identifiers; link tray, device set, and patient to load ID.
Use barcode/QR labels to reduce handwriting errors and support remote admin checks.
Keep a cross-reference index: patient → procedure date → load ID → cycle record → chemical indicator result.

Result: No more “mystery pouches.” Every instrument now has a paper-and-digital trail.

5) Benchtop Steriliser: Validation Without Guesswork

What the records must show

Commissioning/validation aligned with AS 5369 and manufacturer specs.
Routine monitoring and maintenance: daily/weekly checks recorded; faults escalated and closed out.
Load release discipline: cycle record plus chemical indicator per load, signed by the responsible clinician or sterilisation lead.

Practical tip

Create a standing monthly appointment with your service provider and a quarterly internal validation review. Make it visible in the practice calendar so locums and remote coordinators follow the same drumbeat.

6) People, Proof, and the Single Source of Truth

Competency that stands up in an audit

Role-specific competencies with dates, assessors, and evidence (photos, sign-offs, quiz results).
Onboarding micro-lessons for new or remote staff: five-minute videos embedded inside each SOP.
Annual refreshers and spot checks: two signatures—trainee and assessor.

What goes in the manual

Include clear, evidence-backed statements your team can follow, for example: “All patients rinse with chlorhexidine gluconate 0.12% before treatment. Patients wear protective eyewear. Hands are washed with an antimicrobial cleanser before procedures.” The ADA streamlines dynamic information into practical guidance—leverage it. When the manual is the single source of truth, remote workers follow the same steps as those on-site.

7) Waterline Control and the Mock Audit: Resolution

Closing the last gaps

Dental unit waterline schedule: documented shock and maintenance protocol, logs retained, and outcomes reviewed monthly.
Point-in-time verification: in-practice testing results filed with corrective actions if thresholds are exceeded.
Internal audit this month: cross-check every SOP against Dental Board and ADA guidance; record findings and corrective actions within seven days.

Two weeks later, Mia’s mock audit showed zero major nonconformances. Traceability was airtight, steriliser validation current, the manual aligned to AS 5369 and Dec 2024 implementation guidance, and staff competencies up to date. The practice was audit-ready—well ahead of 2025 checks.

8) The Takeaway: Make Compliance a Business Advantage

Rapid checklist to start today

Run a documented internal audit this month.
Map every IPC procedure to Dental Board and ADA resources.
Enforce load release: cycle record plus chemical indicator per load.
Evidence staff competency with a live matrix and sign-offs.
Maintain a waterline schedule with logged outcomes and actions.
Consolidate everything into a single source of truth—and retire outdated copies.

All practitioners are expected to know how to use infection prevention and control systems to provide safe and effective care. Treat documentation as an asset: it protects patients, your team, and your brand. Start now, finish early, and meet 2025 with confidence.

Audit-Ready Dentistry: AS 5369 by 2025