| FAQ - Personal Protective Equipment (PPE) - 2015
Are all dental clinic/office personnel required to wear scrubs per OSHA? and is the a specific type of material these must be made of?
This is actually two Ask OSAP questions.
First, as OSHA states in a letter of standard interpretation, employees' uniforms or scrubs which are usually worn in a manner similar to street clothes are generally not intended to be PPE.1 Thus, scrubs can generally be considered as a substitute for street clothing and are categorized as such.
As Infection Control and Management of Hazardous Materials for the Dental Team notes:
Appropriate protective clothing such as gowns, aprons, lab coats, clinic jackets, or similar outer garments are to be worn in occupational exposure situations. The employer must evaluate the task to determine the appropriate nature of the protective clothing to be used…….Thus the outer covering is the protective clothing that the employer must provide. 2
Second, regarding the type of fabric, Ask OSAP is not aware of any specific fabric or fabric blend requirements for lab coats or scrubs used in dentistry. There are lab coats and scrubs 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:
Personal Protective Equipment --
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.3
The 2003 CDC guidelines for infection control in dentistry states the following:
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, Ask OSAP is not aware of any specific fabric or fabric blend requirements for dental lab coat or scrubs fabric. What is important is that in the case of PPE clothing fabric is that it prevent contamination of street clothing and protect the skin of DHCP from exposure to blood and body substances.
1) US Department of Labor - Occupational Safety & Health Administration. Letter of Interpretation. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27008 Accessed on August 19, 2015.
2) Miller CH. Infection Control and Management of Hazardous Materials for the Dental Team, 5th edition. Elsevier/Mosby Publishers. Page 83.
3) 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 August 19, 2015.
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 August 19, 2015.