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FAQ - Personal Protective Equipment - 2015
 FAQ - Personal Protective Equipment - 2015

 

 

I am hoping you can help me with something that we struggle with in our clinics and that is exposed skin on the leg and the types of shoes that are worn. Our students are required to wear scrubs, socks that cover the ankle, and surgical clogs or athletic shoes. There is no clinical dress code for faculty; consequently, we have some women faculty that wear dresses (or skirts) with bare legs along with high heeled shoes with an open heel. Even though they must wear a disposable gown, the leg is still exposed.

I have looked through the Guidelines for Infection Control in Dental Health Care Settings from 2003 and cannot find anything about bare legs and open heel shoes. What would you say?

Ask OSAP can provide you with some general information pertaining to these issues.

First, regarding clothing.

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. 

Ask OSAP would like to note that OSHA states the following regarding the removal of PPE:

Employers must ensure that workers remove personal protective equipment before leaving the work area. If a garment is penetrated by blood or OPIM, it must be removed immediately or as soon as feasible. Once PPE is removed, it must be placed in an appropriately designated area or container for storage, washing, decontamination, or disposal. In addition, employers must ensure that workers wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment. 4

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. PPE should be removed prior to leaving the work area.

Second, regarding shoes. 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 5

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.  6

OSHA also has a letter of interpretation regarding shoes and it can be accessed here:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24639  7

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:  

https://osap.site-ym.com/?Issues_CrocNot  8

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.

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 June 29, 2015.

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)     US Department of Labor - Occupational Safety & Health Administration. OSHA Fact Sheet - Personal Protective Equipment (PPE) Reduces Exposure to Bloodborne Pathogens. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact03.html   Accessed on June 29, 2015.

5)     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 June 30, 2015.

6)     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 June 30, 2015

7)     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 June 30, 2015.

8)     Organization for Safety, Asepsis and Prevention. Croc Not Shoe Issue. https://osap.site-ym.com/?Issues_CrocNot   Accessed on June 30, 2015.

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