| FAQ - Personal Protective Equipment (PPE) - 2015
Is shoes in the clinical dental office considered PPE ? If so, should dental office provide them?
The employer is required to conduct a workplace hazard assessment and determine which PPE is appropriate for the workplace.
OSHA’s General Duty Clause states as follows:
OSHA's General Duty Clause Section 5(a)(1) OSH Act says:
(a) Each employer --
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees 1
OSHA’s PPE standard states as follows:
OSHA's Personal Protective Equipment Standard 1910.136 states:
29 CFR 1910.136(a) requires the use of protective footwear when employees are working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where there is a possibility of the employee's feet being exposed to an electrical hazard. 2
OSHA also has a letter of interpretation regarding shoes and it can be accessed here:
OSAP does have some information posted on its website which pertains to shoes, and specifically Croc shoes. This information can be accessed at this link:
The CDC does not address the issue of clinic/work shoes, however, dental infection control experts state that each dental office (employer) must determine what is appropriate for their specific office setting, keeping in mind that they should be sensible, comfortable, and practical.
Practical Infection Control in Dentistry contains the following reference to shoe covers:
Head and Shoe Covers
Head and shoe covers are less frequently used types of PPE, but should be considered if contamination is likely. OSHA does not mandate the use of shoe and head covers in dentistry. DHCP may want to consider using shoe covers when contamination of footware is anticipated, such as during surgical procedures where unusually heavy bleeding may be anticipated, (e.g., maxillofacial reconstructive surgery and trauma surgery). Head covers are optional but may be useful in decreasing contamination of DHCP during ultrasonic scaling, surgical procedures using rotary or ultrasonic instrumentation, and manual decontamination of dental instruments, where spraying and spattering of blood and OPIM may be generated. Head covers also provide maximum protection to patients during surgical procedures. 5
1) US Department of Labor - Occupational Safety & Health Administration. Sec 5 Duties. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_id=3359 Accessed on September 25, 2015.
2) US Department of Labor - Occupational Safety & Health Administration. 1910.136. Personal Protective Equipment Standard. hazard. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9786 Access on September 25, 2015
3) US Department of Labor - Occupational Safety & Health Administration. Standard Interpretation. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24639 Accessed on September 25, 2015.
4) Organization for Safety, Asepsis and Prevention. Croc Not Shoe Issue. https://osap.site-ym.com/?Issues_CrocNot Accessed on September 25, 2015.
5) Molinari JA and Harte JA. Practical Infection Control In Dentistry – Third Edition. Wolters Kluwer / Lippincott / Williams & Wilkins. Page 112.