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Messages Forum>
OSHA's interpretation of PPE
Vanessa A
1 post
Jun 08, 2010
4:34 PM
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Hello!
My name is Vanessa and I'm an RDA at a dental office in Granite Bay, California. Our dental office has monthly meetings that cover topics to be compliant with OSHA standards, and this one question keeps coming up that I was really hoping that you could help us with. Here it is....While in a procedure that possibly puts us in contact with saliva, blood or OPIM, how much of our knees/neck needs to be covered? Our doctor that we work for seems to believe that we all should wear plastic sheet/covering to cover our scrubs all the way to the floor. When i think about this though the thought comes to me that we would need then a plastic covering for our scrub jackets as well !!( we all wear scrub pants and tops with jackets that come up to our collar bone) I would just like to hear from an expert (you!) on what is the right thing to do, and what would be in compliance with OSHA standards so we can finally put this question to rest....Thank you so much for your time!
~Vanessa
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thomaskappil
36 posts
Jun 09, 2010
4:38 PM
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Thank you for the question.
This is OSHA’s interpretation dated 07/01/1994 for a similar question regarding appropriate quality standards for personal protective equipment, in particular, clothing.
OSHA's Bloodborne Pathogen Standard requires appropriate PPE to be used to prevent blood or OPIM from passing through to, or contacting the employees' work or street clothes, undergarments, skin, eyes, mouth, or other mucous membranes, unless engineering controls and work practices have eliminated occupational exposure. The type and amount of PPE shall be chosen to protect against contact with blood or OPIM based upon the type of exposure and quantity of these substances which can be reasonably anticipated to be encountered during the performance of a task or-procedure. A gown which is frequently ripped or falls apart under normal use would not be considered "appropriate PPE".
Use of protective body clothing, such as gowns, aprons, laboratory coats, clinic jackets, surgical caps, or shoe covers, and the degree to which such PPE must resist penetration, are performance based. The employer must evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective clothing in accordance with section (d)(3)(i) of the standard. For example, laboratory coats or gowns with long sleeves shall be used for procedures in which exposure of the forearm to blood or OPIM is reasonably anticipated to occur. However, if the amount of blood exposure is such that the blood penetrates the clothing and contaminates the inner surface, the penetration itself would constitute exposure and the clothing would be inappropriate.
OSHA directs compliance officers to evaluate the task being performed and the degree of anticipated exposure by direct observation, employee interview, or review of written standard operating procedures.
As far as your specific situation goes, OSHA regulation does not require a plastic sheet or covering to cover the PPE that you are already wearing. From your email, you mention that you use scrubs pants and tops including jackets, which are fairly adequate PPE. If there is a blood splatter risk, there is a requirement to use an appropriate face shield to protect your eyes and nose. Eye wash station will also be necessary near the work area in case there is an accidental exposure to your eyes.
I hope I have answered your question. Thank you for writing to us.
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