| FAQ - Personal Protective Equipment (PPE) - 2015
I understand that the PPE must be removed before leaving a work area, but in the case of the gowns, can you define work area? Is this just before entering break room, bathroom or leaving the building? Does the gown need to be removed when going into the waiting room to escort a patient back to the patient care area, or does it have to be removed when leaving the treatment area? The term "work area" leaves a lot of room for interpretation from staff.
Ask OSAP can provide you with some general information. Ask OSAP cannot provide you with interpretations of OSHA standards.
From the standpoint of general information, OSHA does have Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens which can be accessed at this link:
This document provides OSHA compliance officers with more specific information regarding the enforcement of the Bloodborne Pathogens Standard. It states in part:
1. Paragraph (d)(3)(vii). To minimize migration of contamination beyond the work area, employees must remove any contaminated clothing before leaving a work area (i.e. before they may enter designated lunchrooms or break rooms). Failure to wash up would be cited under (d)(2)(iv), (v) or (vi). INSPECTION AND CITATION GUIDELINES. While "work areas" must be determined on a case-by-case basis, a work area is generally considered to be an area where work involving occupational exposure occurs or where the contamination of surfaces may occur. The standard would not require employees to change PPE when traveling, for example, from one hospital laboratory area to another, provided the connecting hallway is also considered to be a work area. The Compliance Officer should evaluate on a case-by-case basis whether the employee received adequate training in accordance with paragraph (g)(2)(vii)(F) to ensure that no surface contamination occurs during the employee's movement. A violation would exist for the following: An employee wearing contaminated gloves exits from a pathology laboratory to use a public telephone located in a public hallway of the hospital. Under such circumstances, it can be reasonably anticipated that another employee, without benefit of gloves or knowledge of the potential surface contamination, could use the phone and unwittingly become contaminated.
Since Ask OSAP does not provide interpretations of OSHA standards, it is recommended that you contact your area OSHA office for further information. If you are in a state with an approved state OSHA program, further information about that type of program can be found at this link:
1. US Department of Labor – Occupational Safety & Health Administration. Enforcement Procedures
for the Occupational Exposure to Bloodborne Pathogens.
Accessed on August 5, 2015.
2. US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. http://www.osha.gov/dcsp/osp/faq.html Accessed on August 5, 2015.