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FAQ - Personal Protective Equipment - 2014
 FAQ -  Personal Protective Equipment -  2014

 

 

Scrubs/Lab coats: We have recently heard some recommendations for scrubs/lab coats and we would like to verfiy our findings in guidelines. Our practices currently wear scrub pants and a warm up jacket (snapped to the top with banded sleeves. The jacket and pants are put on in the practice and removed prior to leaving and are laundered by a contracted service. We understand the guidelines to be a lab coat that extends nearly to the knee, so to cover the entire lap area when seated...thinking we are ok, as our entire body-legs are covered...?? Also, are there any requirements for the fabric to be fluid resistant? We do see the CDC guideline stating that lab coats must be switched out when visivly soilded or penetrated by blood or POI fluids. Please share with us what you know about this to help us to make the best decision to ensure compliance. Thank you

This is actually two Ask OSAP questions. First, Ask OSAP would like to address the issue of the length of the gown/lab coat.

With regard to compliance, OSHA’s Bloodborne Pathogens Standard 29 CFR 1910.1030 states that it is the responsibility of the employer to determine what Personal Protective Equipment (PPE) is appropriate. However, they also state that PPE will only be considered appropriate if it prevents blood and other potentially infectious materials from reaching the skin and clothing.

OSHA’s Bloodborne Pathogens Standard 29 CFR 1910.1030 includes requirements for PPE. PPE is only considered appropriate if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. 1

OSHA regulations state, "general work clothes" are not covered by the Bloodborne Pathogens Standard unless they are intended to function as PPE. The dentist/employer should first determine if the clothing worn under the outer protective garment (PPE) will be considered "general work clothes" only, or if they are also intended to function PPE. 1

OSHA defines Personal Protective Equipment as: specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes (e.g., uniforms, pants, shirts or blouses) not intended to function as protection against a hazard are not considered to be Personal Protective Equipment. 1

OSHA’s Bloodborne Pathogens Standard states as follows:

Personal Protective Equipment -- 1910.1030(d)(3)(i)

Provision. When there is occupational exposure, the employer shall provide, at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. 1

1910.1030(d)(3)(xi)

Gowns, Aprons, and Other Protective Body Clothing. Appropriate protective clothing such as, but not limited to, gowns, aprons, lab coats, clinic jackets, or similar outer garments shall be worn in occupational exposure situations. The type and characteristics will depend upon the task and degree of exposure anticipated. 1

Some dental infection control experts recommend the use of knee length gowns. For example, the authors of OSAP Interact:  Infection Control & Safety Training System, state the following:

Long-sleeved, high-collared laboratory coats that completely cover the torso may be the best barrier for exposed skin.  Lab coats may also decrease the need for complete changes of street clothing at the end of the work day. Also, considering the amount of time dental healthcare workers spend sitting with knees on either side of a patient’s head, it is likely that an area receiving a significant amount of foreign matter and splatter may be the thigh and knee area.  For this reason, including reusable (washable) full-length pants as part of protective attire might be appropriate if the lab coat doesn’t cover the upper legs. 2

The authors of From Policy to Practice: OSAP’s Guide to the Guidelines state the following:

The garment should protect skin and street clothes that could become contaminated.  The design and features should include:

  • High-necked/high-collared
  • Long sleeves
  • Covers the knees when seated (if performing sit-down dentistry)3

We are also aware of dental schools, dental hygiene programs, and dental assisting programs that require all faculty and students to wear knee length protective garments.  They have determined that knee length is the most appropriate style because they cover a greater proportion of the workers clothing than the waist length. 

In summary, it is the employer’s responsibility to determine what PPE is appropriate. Personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.1 Knee length protective garments will cover a greater proportion of the worker’s clothing.

Second, regarding the type of fabric, Ask OSAP is not aware of any specific fabric or fabric blend requirements for lab coats used in dentistry. There are lab coats of multiple fabric types currently available on the market. Durability and launderability may be a consideration when selecting fabric. There are also disposable lab coats made of non-woven materials.

According to the US Department of Labor – Occupational Safety & Health Administration’s (OSHA’s) Bloodborne Pathogens Standard:

1910.1030(d)(3)

Personal Protective Equipment --

1910.1030(d)(3)(i)

Provision. When there is occupational exposure, the employer shall provide, at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.1

The 2003 CDC guidelines for infection control in dentistry states the following:

Protective Clothing

Protective clothing and equipment (e.g., gowns, lab coats, gloves, masks, and protective eyewear or face shield) should be worn to prevent contamination of street clothing and to protect the skin of DHCP from exposures to blood and body substances (2,7,10,11,13,137). OSHA bloodborne pathogens standard requires sleeves to be long enough to protect the forearms when the gown is worn as PPE (i.e., when spatter and spray of blood, saliva, or OPIM to the forearms is anticipated) (13,14). DHCP should change protective clothing when it becomes visibly soiled and as soon as feasible if penetrated by blood or other potentially infectious fluids (2,13,14,137). All protective clothing should be removed before leaving the work area (13).4

In summary, we are not aware of any specific fabric or fabric blend requirements for dental lab coat fabric. What is important is that the fabric prevent contamination of street clothing and proctect the skin of DHCP from exposure to blood and body substances.

Resources

1)     US Department of Labor - Occupational Safety & Health Administration. 1910.1030 Bloodborne Pathogens. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051  Accessed on December 17, 2014.

2)     Organization for Safety, Asepsis and Prevention. OSAP Interact:  Infection Control & Safety Training System. Published by OSAP. 1999.

3)     Organization for Safety, Asepsis and Prevention. From Policy to Practice: OSAP’s Guide to the Guidelines. Published by OSAP. 2004.

4)     Kohn WG, Collins AS, Cleveland JL, Harte JA, Eklund KJ, Malvitz DM, Centers for Disease Control   and Prevention (CDC). Guidelines for infection control in dental health-care settings—2003. MMWR Recomm Rep 2003;52(RR-17):1-61. http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm  Accessed On December 17, 2014.

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