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The IPC Lead's Role in a CQC Inspection: An HTM 01-05 Checklist
When the Care Quality Commission (CQC) inspects a dental practice, the registered provider and registered manager are accountable for meeting the regulations, but it is usually the IPC lead who runs infection control day to day and holds the evidence inspectors want to see. To find out what that means in practice, Dental Nurse Network reviewed a sample of 33 recent CQC dental inspection reports, published between June 2024 and August 2026. Every one of them checked the same core areas, and almost half noted at least one infection control gap, even though all 33 practices were found to be meeting the regulations. This checklist brings those findings together with HTM 01-05 and the Code of Practice, so IPC leads know exactly what to have in place before inspectors arrive.
What CQC inspectors look at
The infection control section of a CQC dental report follows the same pattern almost every time. Across the 33 reports we reviewed, inspectors checked these nine areas:
| Area | Reports that covered it |
|---|---|
| Infection control procedures in line with published guidance | 33 of 33 |
| Staff training and knowledge | 33 of 33 |
| Legionella procedures and risk assessment | 33 of 33 |
| Cleaning protocols | 33 of 33 |
| Infection control audits | 33 of 33 |
| Equipment maintained and serviced | 33 of 33 |
| PPE and decontamination of instruments | 32 of 33 |
| Single-use items never reprocessed | 32 of 33 |
| Segregation and disposal of hazardous waste | 32 of 33 |
In England, CQC uses the Code of Practice on the prevention and control of infections to judge whether a practice meets the infection control requirement in Regulation 12 (safe care and treatment) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and the Code points dental practices to HTM 01-05 for decontamination. That is why the checklist below follows HTM 01-05 so closely.
The IPC lead's role in the inspection
CQC's guidance for dental providers says most inspections are announced, usually with about two weeks' notice by phone and letter, although CQC can arrive unannounced if it has concerns. That notice period is when the IPC lead's preparation pays off.
Who is responsible for what. The registered provider and the registered manager are legally accountable to CQC, and it is the registered manager, or another senior person, whom the inspector meets at the start of the visit. The Code of Practice says the IPC lead reports directly to the registered provider. The Code allows the IPC lead to be the registered provider, the registered manager or another member of the team, such as a dental nurse. Whoever holds the role, the IPC lead's part is to make sure the infection control systems work, the records are complete, and the manager knows about any gaps before inspectors find them.
Before the visit. The lead inspector asks for information in advance and phones the practice to ask about its systems and processes. The IPC lead should make sure the infection control evidence is up to date and easy to find. CQC's own list of documents to have ready includes infection control policies, procedures and records, audits and action plans, equipment maintenance certificates, training records and risk assessments.
On the day. Inspectors watch processes being carried out, including decontamination, look around the premises and read policies and records. They also talk to staff, including dental nurses. Reports regularly use phrases such as "we saw, and staff confirmed", so what the team says needs to match what the paperwork says. The IPC lead does not need to answer every question personally, but should have prepared the team so that anyone asked can explain what they do and why.
At the end. The lead inspector gives initial feedback, including anything that needs immediate action. Several of the reports we reviewed noted that the practice sent evidence straight after the visit to show a gap had been fixed. Acting quickly on feedback is part of the IPC lead's role too.
Daily checks
These are usually carried out by whoever is working in the surgery or decontamination room. The IPC lead's job is to make sure they happen and are recorded.
- Autoclaves are tested before use each day: an automatic control test and, for vacuum (type B) autoclaves, a steam penetration test such as a Helix test. Results are recorded.
- Ultrasonic baths and washer-disinfectors have their strainers and filters cleaned, are drained at the end of the day, and each load is checked to make sure instruments come out visibly clean.
- Dental unit water lines are flushed for at least two minutes at the start and end of the day, and for 20 to 30 seconds between patients. Self-contained water bottles are emptied, flushed with distilled or reverse osmosis water and left open to dry overnight.
- Surfaces near the dental chair are cleaned between every patient, including the chair, work surfaces, lights, the spittoon and the aspirator. Taps, sinks and splashbacks are cleaned after each session.
- Unwrapped instruments kept in the surgery are stored dry and protected, in closed drawers or covered inserts and never on open worktops, and are reprocessed at the end of the day, or at the start of the next working day, whether they were used or not.
- Clinical waste is segregated in line with HTM 07-01, using foot-operated bins in clinical areas, and waste awaiting collection is kept in a locked, secure bin.
- Records for all of the above are completed and signed. In the reports we reviewed, inspectors repeatedly flagged checks that may have been done but were not written down.
Weekly and monthly checks
- Protein residue tests are carried out weekly on ultrasonic baths and washer-disinfectors, along with their weekly safety checks, unless the manufacturer sets a different schedule.
- Water temperatures are checked and recorded as the practice's Legionella risk assessment requires, which is usually monthly. Several practices in our review were caught out by hot water not reaching the required temperature, or by checks done incorrectly.
- Little-used taps and outlets are flushed as often as the Legionella risk assessment says, and the flushing is logged. Missing flushing records came up in more than one report.
- Dental unit water lines are disinfected periodically, following the manufacturer's instructions, and the method is written into the surgery checklists so every nurse does it the same way.
- Spot checks by the IPC lead show what really happens day to day: whether pouches are dated and in date, whether PPE is worn correctly, whether waste is separated properly and whether daily records are complete. A simple rota for spot checks keeps them regular.
Quarterly, six-monthly and yearly checks
Every quarter
Ultrasonic baths and washer-disinfectors have quarterly tests, usually carried out by a service engineer, unless the manufacturer sets a different schedule.
Every six months: the infection control audit
HTM 01-05 asks every practice to audit its decontamination at least every six months, and recommends the Infection Prevention Society audit tool. This was the second most common gap in our review. Inspectors flagged audits done only once a year, audits that did not match what they saw on the day, and audits with no action plan. A good audit is honest, is checked against what actually happens, and ends with an action plan that is followed up. Audit records are kept for at least two years.
Every year
- Autoclaves are serviced and validated, and pressure vessels are examined by a competent person in line with the practice's written scheme. One practice in our review had an autoclave overdue for all three.
- Ultrasonic baths and washer-disinfectors are revalidated, and again after any major repair.
- The annual IPC statement is written and kept on record. The Code of Practice says it should briefly review any significant incidents, the audits and risk assessments carried out, staff training, and updates to policies.
- Training records are checked, so every team member has had induction and refresher infection control training, including hand hygiene.
At least every two years
- The infection control policy is reviewed at least every two years, which is the maximum HTM 01-05 allows. Reviewing it each year, when writing the annual IPC statement, keeps it current.
Whenever things change
- The Legionella risk assessment has no fixed review date. The Health and Safety Executive expects it to be reviewed regularly, and whenever there is reason to think it is no longer valid, such as when surgeries are reconfigured. It must be carried out by a competent person. Both problems came up in our review.
Where practices get caught out
All 33 practices in our review were found to be meeting the regulations on infection control, but 15 still had gaps written into their reports. Most of them came down to records not matching reality.
| Gap | Reports | What inspectors found |
|---|---|---|
| Legionella and water | 9 | Hot water below the required temperature, missing flushing logs, out-of-date risk assessments |
| Infection control audits | 5 | Annual instead of six-monthly, not matching practice, no action plan |
| Instruments | 3 | Dirty instruments pouched for use, pouches dated beyond 12 months, single-use items reprocessed |
| Equipment testing and servicing | 3 | Missing ultrasonic validation checks, autoclave overdue service and inspection |
| Waste | 3 | Waste not segregated properly, clinical waste bins not lockable |
| Cleaning | 3 | No cleaning schedules, decontamination room needing improvement |
| Annual IPC statement | 1 | No statement available |
Very few of these gaps needed new equipment or building work. Most could have been caught by an IPC lead with a regular routine, complete records and audits that are followed through.
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Further reading
Written by Dental Nurse Network. Last updated November 2026.