Employer laundering of contaminated surgical caps

June 22, 2007

Mr. John Noll, RN, MBA, CNOR

OR Infection Surveillance & CQI

The Reading Hospital and Medical Center

[Recipient address omitted]

Dear Mr. Noll:

Thank you for your April 5, 2007 letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to OSHA's Directorate of Enforcement Programs (DEP) for a response. You had concerns regarding the interpretation of OSHA's bloodborne pathogens standard as it relates to laundering of surgical caps contaminated with blood from the operating room. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question(s) not delineated within your original correspondence. Your question is restated below, followed by OSHA's response.

Question: Please clarify the requirements of the bloodborne pathogens standard (29 CFR 1910.1030). Should employees be allowed to take home reusable surgical caps contaminated with blood for laundering or is the employer required to launder such items?

Reply: As you may know, the primary use of surgical caps in operating rooms is to provide protection to the patient from any organisms that may shed from the hair or scalp of surgical staff. However, 1910.1030(d)(3)(xii) recognizes that in some circumstances surgical caps and/or hoods may be necessary to prevent splashes of blood or other potentially infectious material (OPIM) from the surgical site onto the surgeon(s) and/or others in the operating room. If it can be reasonably anticipated that the operating room employee's heads may be contaminated with blood or OPIM, appropriate surgical caps and/or hoods may be necessary PPE. Therefore, if staff members are provided surgical caps which are considered an appropriate level of protection for workplace conditions and it is worn, relied upon, and/or functions as a protective garment, then the surgical caps would be covered by the requirements of the standard and the contaminated surgical caps must be laundered by the employer at no cost to the employee. With regard to contaminated personal protective equipment, OSHA has stated in CPL 02-02-069 XIII.D.16, that "home laundering is unacceptable because the employer cannot ensure that proper handling or laundering procedures are being followed and because contamination could migrate to the homes of employees" Employers are responsible for cleaning, laundering and/or disposing of personal protective equipment [29 CFR 1910.1030(d)(3)(iv)].

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Richard E. Fairfax

Directorate of Enforcement Programs