OSHAs expectations from bloodborne pathogens rule

The bloodborne pathogens standard contains a variety of rules related to the selection and use of personal protective equipment.

The bloodborne pathogens standard contains a variety of rules related to the selection and use of personal protective equipment.

Chris Miller, PhD

OSHA`s bloodborne pathogens standard that affects all dental offices is sometimes difficult to interpret. As a result, OSHA periodically publishes a Compliance Direct-ive for OSHA inspectors who must determine compliance with the standard during an onsite visit. The document describes these enforcement procedures by providing inspection guidelines and citation guidelines.

The most recent Compliance Directive appeared in November 1999 (CPL 2-2.44D). The following is a review of this information relative to personal protective equipment.

What is exposure?

According to OSHA, exposure occurs when blood or other potentially infectious material (OPIM) - such as saliva in dentistry - passes through to, or contacts, the employee`s work or street clothes, undergarments, skin, eyes, mouth, or other mucous membranes. Thus, the standard indicates that personal protective equipment (PPE) is to be used by employees to prevent these exposures.

Types of PPE

During times of potential exposure, gloves need to be worn, the eyes need to be protected with glasses that have solid-side shields, mucous membranes of the nose and mouth need to be protected with a mask, and skin and underlying garments need to be protected with protective clothing. In dentistry, PPE includes gloves, mask, protective eyewear, and protective clothing.

The specific types of PPE are chosen by the employer to protect against anticipated exposure. Thus, the selected PPE must be able to prevent the types of exposure that can be reasonably anticipated to occur in the office. For example, if the forearms may be exposed to blood or saliva, then long-sleeve rather than short-sleeve protective clothing is indicated.

The employer has the financial responsibility for purchasing and providing the PPE to employees. The employer is not obligated to provide general work clothes to employees. However, if a uniform is intended to protect the employee`s body from contamination, the uniform is to be provided by the employer at no cost to the employee. Scrubs are usually worn in a manner similar to street clothes, and normally would be covered by appropriate gowns when exposure to skin or clothes is reasonably anticipated.

As mentioned above, "appropriate" PPE must be provided. This includes appropriate sizes in addition to alternatives (e.g., nonlatex gloves) for those who need them.

A good example is OSHA indicating that food-handling gloves ("cafeteria" or `baggie" gloves) are not considered appropriate for use in exposure-related tasks. These gloves would not properly fit the employee as required by the standard.

Uses of PPE

The standard requires that PPE is readily available and that employees use PPE when exposure can be reasonably anticipated. An exception to using PPE may occur in very special circumstances where the use of PPE may put a patient`s life in danger.

PPE must not be worn out of the "work area." The work area would be places where occupational exposure may occur or surfaces become contaminated with blood or OPIM. For example, the protective clothing worn at chairside is not to be worn into break rooms, or lunchrooms, or out of the office.

It is the employer`s responsibility to clean, repair, maintain, replace, and/or dispose of PPE, and employees cannot take protective clothing home to launder. Home laundering by employees is not permitted since the standard indicates that laundering is the responsibility of the employer and is to be performed at no cost to the employee.

Home laundering is unacceptable because the employer cannot ensure that proper handling or laundering procedures are being followed and because contamination could migrate to homes of employees.

Handwashing is related to the use of gloves and OSHA requires handwashing after removing gloves. OSHA also states that disposable gloves are not to be washed or reused.

Examples of noncompliance

According to the November 1999 OSHA Compliance Directive, specific examples when citations related to PPE are to be given include:

- PPE is not provided at no cost to the employee;

- PPE is not available in appropriate sizes or readily accessible;

- PPE is not being used during situations where exposure to blood or OPIM could be anticipated;

- Resucitator devices that prevent exposure are not readily available and accessible to those who can be expected to use them or training for their use is inadequate;

- PPE is not being used properly;

- The wrong PPE is being used;

- The wrong size PPE is being worn;

- Training on the types, use, limitations, and locations of PPE is not provided to employees;

- PPE is not cleaned, laundered, and disposed of by the employer;

- The employer cleans the PPE but charges the employee for this cost;

- PPE is not repaired or replaced by the employer at no cost to the employee;

- PPE is not removed as soon as possible when penetrated by blood or OPIM.

In summary, the bloodborne pathogens standard contains a variety of rules related to the selection and use of personal protective equipment.

Chris Miller, PhD, is professor of oral microbiology and associate dean at the Indiana University School of Dentistry.

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