Ask the expert—Laundering scrubs

By: David LaHoda November 5th, 2008 Email This Post Print This Post

Q: What does OSHA say about the home laundering of scrubs?

A: If in your facility scrubs do not function as personal proactive equipment (PPE)—most scrubs function as uniform and not PPE—then OSHA does not have oversight on laundering.

If the scrubs function as PPE, then the employer is in violation of the bloodborne pathogen standards by having employees clean, launder, and maintain them on their own:

1910.1030(d)(3)(iv)
Cleaning, Laundering, and Disposal. The employer shall clean, launder, and dispose of personal protective equipment required by paragraphs (d) and (e) of this standard, at no cost to the employee.

If non-PPE scrubs are becoming contaminated with blood or OPIM, you should have a policy that deals with how those garments are cleaned. For example, send it to a commercial cleaner identified as blood contaminated, or decontaminate the garment (probably with bleach) before sending home for cleaning. Include this information in your exposure control plan.

If this is a frequent situation, OSHA would question whether you are providing the proper training or adequate PPE selection for your employees.

Personal Protective Equipment Training Video: Comply with OSHA’s Bloodborne Pathogens Standard is a good source for PPE-specific training in healthcare facilities. Click on the link for a short preview of the video.

Are contaminated scrubs a problem in your healthcare facility, or do you have a policy on how to handle non-PPE contaminated work garments? Post a comment below.

Comments

By Jeanne Thompson on November 19th, 2008 at 11:25 am

My question is about sheets and blankets for patient use and is not PPE for employees. Occasionally a sheet will get blood on it from an IV start and staff has treated the stain prior to sending out for laundry. Staff dons gloves and applies hydrogen peroxide to the stain, rinses and then places sheet in a yellow bag to alert laundry service staff. This has been done to prevent a stain from setting as the laundry service does not pretreat and the sheet comes back stained. Recent research by staff indicates this is against OSHA regs and that the contaminated sheet should not be treated prior to sending to laundry service. Can you clarify this for me?

By David LaHoda on November 19th, 2008 at 3:15 pm

Here are the two sections of the bloodborne pathogens standard relevant to your contaminated laundry question:

1910.1030(d)(4)(iv)(A)
Contaminated laundry shall be handled as little as possible with a minimum of agitation.

1910.1030(d)(4)(iv)(A)(1)
Contaminated laundry shall be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use.

Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, the document that OSHA compliance officers use during inspections elaborates:

Paragraph (d)(4)(iv). This paragraph reduces employee exposure to bloodborne pathogens by reducing the amount of manual handling of contaminated laundry. Restricting the sorting to the laundry area will also reduce contamination of additional surfaces.

INSPECTION AND CITATION GUIDELINES. Paragraphs (d)(4)(iv)(A) and (A)(1) limit the handling of laundry to removal and bagging or containerization. The compliance officer should check the laundry collection program as well as the training of the employees assigned to these tasks.

So, yes, handling laundry more than necessary or sorting or rinsing in the location of use is a violation. Treating contaminated laundry in a designated laundry area, however, would not be a violation, according to the enforcement procedures document.

By Michael McDonnell on January 4th, 2009 at 3:10 pm

Can you tell me if regular scrubs, not scrubs provided by the hospital, worn by nurses need or have to have AAMI standards? Does the AAMI put standards on scrubs?
Can a scrub prevent health care workers from airborne pathogens?

By David LaHoda on January 21st, 2009 at 3:57 pm

Scrubs are not usually considered personal protective equipment (PPE) and neither AAMI nor ASTM award certification to scrubs for protection from pathogens. Surgical gowns, isolation gowns, and other PPE for healthcare settings do carry certification, but not scrubs.

By Jamie Westin on February 17th, 2009 at 2:47 pm

- Even though most scrubs and lab coats are not considered PPE, there is a company in Pittsburgh that sells “ANSI/AAMI Level 2″ apparel for medical personnel (us paranoids) who want to have that extra protection. Their apparel meets level 2 criteria and it is also protected with an antimicrobial. http://www.onqor.com/onqor_ppe.htm

By David LaHoda on February 17th, 2009 at 2:54 pm

That is good information to have, Jamie, whether you are paranoid or not, which I don’t think you are. I suppose, though, that the purchase of these products come out of your pocket and not your employer’s.

How does a hospital accommodate a female nursing student who does not wear pants. To be forced to do so would go against her conscience. OR scrubs do come in a dress form but cannot be guaranteed to be available by the hospital. Is it appropriate to have them laundered by a facility that meets the standards and then present proof of such? Or would you handle it another way.

By David LaHoda on September 4th, 2009 at 12:32 am

As this is not a federal OSHA concern–scrubs are not considered PPE—and not a safety question, I admit that I am out of my expertise here.

Essentially you have a uniform issue, which usually falls under corporate policy but sometimes state departments of labor have uniform provision and reimbursement regulations.

What is you corporate policy for uniform/scrubs? Does your facility provide them? If so you probably need to make a reasonable accommodation for her preference. If it is the employee’s responsibility to provide the scrubs, your policy should state what is an acceptable uniform for appearance.

Perhaps other readers have faced a similar experience. I can’t believe your situation is unique.

In any event, check with your state’s department of labor for relevant regulations.

Can you let me know if Dental assistants are required to wear PPE and if so what are the options for cleaning them.

thanks

By David LaHoda on November 18th, 2009 at 1:56 pm

PPE is not based on the job title, but the hazards present. It is the employer’s responsibility to identify hazards, address those hazards in the written exposure control plan (ECP), and ensure that workers adhere to those requirements. So, first check your ECP.

HCPro’s OSHA Safety Program for Dental Offices includes a Sample Personal Protective Equipment (PPE) for Dental Office Procedures table on when to use gloves, gowns, and face protection in dental settings. You can download it from the Tools page.

PPE must be cleaned by the employer. That is a requirement by OSHA.

 

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