When safety battles fashion over bloodborne pathogens

By: November 4th, 2008 Email This Post Print This Post

No matter what the season, questions about casual footwear—mostly sandals, clogs, and Crocs—and compliance with OSHA’s bloodborne pathogens standard always seem to crop up.

Maybe it’s global warming that is the cause for all those exposed toes and heels, or is it just that employees are adamant that the workplace not infringe on their sense of foot fashion or comfort?

Casual footwear that exposes feet to injury from dropped contaminated needles and sharps and exposure to chemicals is a legitimate safety concern in healthcare facilities. OSHA says it is the employer’s responsibility to identify the hazard and situations where reasonable occupational exposure exists and to take measures to prevent the exposure.

One measure is to provide personal protective equipment for those exposure-prone situations. Another solution is to make the choice of footwear subject to the business’s dress code. OSHA says, “businesses can make this type of dress code determination without regard to a worker’s potential exposure to blood, OPIM, or any other recognized hazards.”

An OSHA letter of interpretation explains this nicely. Have it ready the next time a sandal-wearing employee wants to go toe-to-toe with you.

For more information on this footwear battle, check out the footwear fashion video clip in the Video Library.

Comments

By Christine Lesser on November 5th, 2008 at 4:08 pm

David,

Thank you for this very valuable article regarding foot wear!!

I would appreciate information regarding laundering scrubs and lab coats at home.
It’s my understanding that OSHA requires scrubs and lab coats to be laundered in water that is 160 degrees F for a minimum of 20 minutes. Laundering at home does not achieve this water temperature. A number of private practice staff say they get around this standard by using bleach when they launder their scrubs at home but vibrant colored scrubs would fade if bleach was used. Please help me locate a definitive answer on this.

All the best,
Christine Lesser
Morgan Healthcare
Livonia, MI
Email: lesserc@morganservices.com

By David LaHoda on November 5th, 2008 at 4:50 pm

Christine:

If the scrubs and lab coats 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 and lab coats 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.

See Ask the expert—Bloodborne: Laundering scrubs for a detailed discussion of this question.

Since you asked about laundering and water temperature requirements, the CDC has recommendations for cleaning contaminated laundry, but this does not apply to employees’ laundering their own PPE.

CDC Guidelines for Laundry in Health Care Facilities:

  • Wash soiled laundry with a detergent in water at least 71º C (160º F) for 25 minutes
  • For low temperature (less than 70º C) laundry cycles, use chemicals suitable for low temperature washing at proper use concentrations
  • Bleach provides an extra margin of safety when a chlorine residual of 50-150 ppm is achieved during the bleach cycle

Remember, handle soiled laundry as little as possible, place it in bags for transporting, use personal protective equipment when sorting, and don’t sort or pre-rinse in patient care areas.

You say do not pre-rinse in patient care areas. Does that include a soiled utility room on the patient care unit? The door to the room is a self closing door, and you need to swipe a card to enter.

By David LaHoda on November 7th, 2008 at 3:21 pm

I believe that situation would meet both OSHA regulatory and accreditation organization compliance.

I’m not clear on the response that soiled patient linen can be rinsed in the “soiled utility room”..would it be transported in impermeable bag from the patient room to the soiled utility room, then rinsed in the hopper, then rebagged in another impermeable bag, labeled as soiled and sent to outside laundry service?

Just wondering,

I am a 3 month recent hired medical assistant to a center for women within a hospital in Boston. When they hired me they did not have a station build for me, so in other words they do not have a desk area for me. So far they requested a station to be build for me but it was denied in the mean while they have set me in the utility room. The utility room is used for the urine specimens and for the dirty instruments. Also the ultrasound people have their desinfectant machine in this room. Is this against osha?

By David LaHoda on December 30th, 2008 at 4:19 pm

It may not be against OSHA regulations, but it’s pretty shoddy treatment by your employer.

If you were not trained under the bloodborne pathogens standard and offered the hepatitis B vaccination at the time you assumed your work location, then it is probably a violation of that standard.

Also, it is not an OSHA violation to work in an area where disinfection chemicals are used, but it is a violation if you were not informed of the hazard by way of the hazard communication standard and if the room air changes and ventilation does not keep meet the permissible exposure levels for that chemical.

Much of this information you are entitled to obtain from the exposure control plan, the written hazards communication plan, and the material safety data sheets for chemicals present at your workplace.

The information on laundering uniforms was very informative, but still not certain as a Dental assistant if the uniform itself can be laundered at home and the lab coat laundered elsewhere by employer. Any information would be helpful. Thankyou.

By David LaHoda on August 3rd, 2009 at 2:22 pm

As a dental assistant, your uniform can be home laundered except if is contaminated with blood and OPIM. Then OSHA says your employer is not ensuring the proper use of PPE and additional training is needed.

As a dental assistant, can you wear long sleeve shirts under your scrub tops? What about in a hospital setting? I’m not sure what OSHA says about this…

By David LaHoda on April 14th, 2010 at 12:01 am

From and OSHA-only perspective, it doesn’t matter since OSHA does not view scrubs as PPE, more as a uniform.

Long sleeve shirts under scrub tops may be an infection control concern but probably not related to occupational health and safety.

I aaume, however that both dental practices and hospitals would have internally-created policies on long sleeves and scrubs.

does anyone have a policy addressing this specific issue?

I work in the toxicology depart at a lab. I am not working with urine or blood. I work in the data entry area which is deemed a clean area. I have to walk the outskirts of the lab to use the restrooms or go to the break room. Am I required to were leather shoes to do this or can I wear a Aspen (similiar to a croc but it covers higher on the front of the foot with no holes and leaves only a small amount of your heel exposed) to work in my department. Also is a sneaker with mesh on it a recommeded footwear in the lab area that is exposed to bloods and urines.

Technically, wearing mesh sneakers is a no-no. The fullest coverage possible is best wherever there is the possibility of contamination exposure, which would include accidental dropping of instruments, sharps, or even drips from instruments being removed from the ultrasonic. These could all go through the mesh onto open skin, or perf intact skin.

If a person is wearing sandals how much weight is she allowed to carry as in electronic equipment (~50 lbs)? My boss said that are no regulations concerning this.

By Cleo Pease on April 4th, 2013 at 10:46 am

What is OSHA’s opinion on Croc’s in the healthcare setting, especially in patient care areas(hospitals). We have an no open toe/heel policy, but we have nurses wearing them with holes/designs cut out in the top of the shoes. Even if they have a heel strap aren’t they still considered an open heel?

Thank you
Cleo

hello i work with furnal homes to remove dead bodies and iwas wondering what i am allowed to wear because my boss is being cheap and wont pay for a full suit just the pants even though it is comeing out of my pay and i am the first woman they have hired and they are trying to dress me like a man …can you give me some examples of what to wear plz

By Christine on July 10th, 2013 at 10:38 pm

I work in a nursing home where the dress code of no open toed, or open backed shoes is not being inforced by the administrator. Secretaries and even the DNS are the violaters. Does OSHA ever make drop in calls to correct situations such as this?

In an emergency or in an evacuation situation. all the staff are expected to hurry to the aide of the residents. The wearing of sandals would inhibit this, and might even jeopardize the life of a resident in the event of a fire. Tripping while trying to rescue a resident, is detrimental. How can I as an employee get this situation corrected?

Is it mandatory for dental assistants and hygienist to wear long sleeves?

Is it mandatory for nurses to wear white lab coats when out in the community giving flu shots?

By Elya Keller on July 17th, 2014 at 12:20 am

I am a dental hygienist and there seems to be confusion in the dental community regarding appropriate PPE, specifically lab coats. Do lab coats have to be long sleeved? Or can you wear short sleeve lab coats and wash hands/arms thoroughly between patients? I’ve been told that there has been evidence that long sleeve lab jackets increase patient cross contamination. So my question, is it ok to wear short sleeve lab coats or is this non compliant?

 

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