Petroleum-based hand creams and latex gloves

August 24, 1993

Geraldine L. Dettman, Ph.D.
President
Viro Research International, Inc.
[Recipient address omitted]
Dear Dr. Dettman:

This is in response to your letter of July 2, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens."

Specifically, you asked whether there is "an official opinion, position or policy for advice to health care and public safety workers, to avoid the use of mineral oil and/or petrolatum containing skin care products that may come in contact with latex gloves."

Although paragraph (d)(2)(ix) of the standard states that applying cosmetics is prohibited in work areas where there is a reasonable likelihood for occupational exposure, hand cream is not considered to be a cosmetic and is permitted. However, it should be noted that some petroleum-based creams can adversely affect glove integrity.

The standard provides that when there is occupational exposure, the employer shall provide "appropriate personal protective equipment." It also states that personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or to 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.

During the rulemaking process, it was brought to OSHA's attention that significant deterioration of latex gloves was noted when exposed to petroleum-based lubricants. (See 56 Federal Register 64119, December 6, 1991.) Therefore, if latex gloves are used, employees shall not apply petroleum-based, including mineral oilbased, skin care products. If appropriate, this information must also be transmitted to employees as part of their required training.

The State of California is one of the twenty-five states which administers its own safety and health program, which is overseen and monitored by Federal OSHA. State plan standards must be at least as effective as Federal OSHA standards, and the state may choose to promulgate and enforce requirements which are stricter than Federal OSHA's. You may therefore wish to contact the California State Plan regarding this issue as well. They may be reached at the following address and phone number:

Director California Department of Industrial Relations 455 Golden Gate Avenue, 4th Floor San Francisco, CA 94102 415-703-4590

We hope this information has been responsive to your concerns. Thank you for your interest in employee safety and health.

Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]