Protective clothing for bloodborne pathogen exposure

July 1, 1994

Mr. Mitchell Davis
President
Protect Aide, Inc.
[Recipient address omitted]
Dear Mr. Davis:

This if in further response to your letter of April 19, addressed to Assistant Secretary of Labor for OSHA, Joseph A. Dear, regarding your concerns about the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." You expressed concerns about appropriate quality standards for personal protective equipment, in particular, clothing.

OSHA has not established specific standards for personal protective clothing resistance against biological agents.

OSHA's Bloodborne Pathogen Standard requires appropriate PPE to be used to prevent blood or OPIM from passing through to, or contacting the employees' work or street clothes, undergarments, skin, eyes, mouth, or other mucous membranes, unless engineering controls and work practices have eliminated occupational exposure. The type and amount of PPE shall be chosen to protect against contact with blood or OPIM based upon the type of exposure and quantity of these substances which can be reasonably anticipated to be encountered during the performance of a task or-procedure. A gown which is frequently ripped or falls apart under normal use would not be considered "appropriate PPE".

Use of protective body clothing, such as gowns, aprons, laboratory coats, clinic jackets, surgical caps, or shoe covers, and the degree to which such PPE must resist penetration, are performance based. The employer must evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective clothing in accordance with section (d)(3)(i) of the standard. For example, laboratory coats or gowns with long sleeves shall be used for procedures in which exposure of the forearm to blood or OPIM is reasonably anticipated to occur. However, if the amount of blood exposure is such that the blood penetrates the clothing and contaminates the inner surface, the penetration itself would constitute exposure and the clothing would be inappropriate.

OSHA directs compliance officers to evaluate the task being performed and the degree of anticipated exposure by direct observation, employee interview, or review of written standard operating procedures.

Regarding the use of gloves as PPE, gloves of appropriate sizes must be made available in accordance with section (d)(3)(iii) of the standard.

At a minimum gloves shall be used where there is reasonable anticipation of employee hand contact with blood, OPIM, mucous membranes, or non-intact skin; when performing vascular access procedures; or when handling or touching contaminated surfaces or items. Studies have shown that gloves provide a barrier, but that neither vinyl nor latex procedure gloves are completely impermeable. Thus, OSHA requires hand- washing after glove removal.

While disposable gloves shall be replaced as soon as practical when contaminated, obviously some critical procedures (i.e., surgery, delivery) cannot be interrupted to change gloves. The key words to evaluate are "practical" and "feasible".

Disinfecting agents may cause deterioration of the glove material; washing with surfactants could result in "wicking" or enhanced penetration of liquids into the glove via undetected pores thereby transporting potentially infectious materials into contact with the hand. For this reason, disposable (single use) gloves may not be washed and reused. Plastic film food handling gloves ("cafeteria" or "baggie" gloves) are not considered to be appropriate for use in exposure-related tasks. They are not strong enough to provide protection to the hands nor would they fit the employee as required by paragraph (d)(3)(ii) of the standard.

There are currently no available standardized methods of testing and classification of performance specifications for resistance of clothing to biological hazards. However, we appreciate your efforts in providing to customers products that have met other agencies' guidelines and regulations with safety in mind.

We hope this information alleviates your concerns. Thank you for your interest in worker safety and health.

Sincerely,
John B. Miles, Jr. Director
Directorate of Compliance Programs

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