Whether CDC recommendations are “law” or not depends on your state’s Dental Practice Act. Some state Dental Practice Acts state to follow CDC recommendations, making them “law.” However, some Practice Acts don’t make mention because following the CDC guidelines is what all offices (no matter the state) should be doing. You can check your state’s Board website and the Dental Practice Act and/or contact the Board for clarification on whether recommendations are stated as “law.”
 
The CDC recommendations state, “…cleaned instruments and other dental supplies should be inspected, assembled into sets or trays, and wrapped, packaged, or placed into container systems for sterilization… Packaging materials (e.g., wraps or container systems) allow penetration of the sterilization agent and maintain sterility of the processed item after sterilization. Materials for maintaining sterility of instruments during transport and storage include wrapped perforated instrument cassettes, peel pouches of plastic or paper, and sterilization wraps (i.e., woven and nonwoven). Packaging materials should be designed for the type of sterilization process being used.”
 
From: https://www.cdc.gov/mmwr/PDF/rr/rr5217.pdf
 
My thoughts… the CDC “recommends” we wash our hands. Whether this is a “law” or not, we all do it. The same thing goes for all of the CDC recommendations. An office cannot ethically pick and choose which recommendations to follow or not. In my opinion, whether its “law” or a “recommendation,” you are correct – cassettes should be wrapped or bagged. How else are they going to stay sterile?!
 
I hope this helps!