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Final rule on worker protection from bloodborne pathogens released by OSHA.

Final Rule On Worker Protection From Bloodborne Pathogens Released By OSHA

in a long-awaited decision, OSHA has finalized its rule on protective apparel requirements in medical applications; provisions will take effect next month

The Occupational Safety and Health Administration (OSHA) has finalized its rule on worker protection from bloodborne pathogens such as AIDS and hepatitis. The rule, which had been strongly encouraged by INDA, Association of the Nonwoven Fabrics Industry, had been under consideration at OSHA for nearly two and a half years. Provisions of the new rule will take effect on March 6, 1992.

The rule is significant to the nonwovens industry because it requires, among other things, that all employers provide personal protective equipment (PPE) to any of their employees who are at risk of exposure to blood or other potentially infectious body fluids.

This action will basically provide the nonwovens industry with an opportunity to expand markets, both to employers who must comply with PPE requirements for the first time, and to employers who currently rely on reusable products but will face new liability for their performance.

Since the rule does not specify that disposables are the better option for compliance, however, it is up to the members of the nonwovens industry to convince those affected by this rule that their products are better suited to compliance than reusables.

General PPE Provisions

The new rule is broadly written to prevent worker exposure to blood and potentially infectious body fluids (defined by OSHA as semen, vaginal secretions, cerebrospinal fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood and any body fluids in situations where it is difficult or impossible to differentiate between body fluids).

The rule requires that universal precautions and engineering controls be adopted that minimize the risk of exposure and if the possibility of exposure exists despite these actions, employers must provide PPE at no cost to the employee.

PPE is defined by OSHA as "specialized clothing or equipment worn by an employee for protection against a hazard" and does not include "general work clothes." OSHA specifies that PPE to be provided includes such items as gowns, laboratory coats, face masks, pocket masks, gloves and ventilation devices. These are just examples noted in the rule, however, and OSHA makes it clear that employers must provide any and all items necessary to protect their workers against exposure.

The rule states that "body clothing" such as gowns, aprons, and lab coats must be worn in "exposure situations," but the type of clothing and its degree of barrier protection will depend on the task being performed and the degree of exposure anticipated.

In addition, the rule specifically states that face masks must be worn (in combination with eye protection) whenever risk can be anticipated of splashes, spray, spatter or droplets of blood or other infectious material coming in contact with the eyes, nose or mouth.

The rule also requires that cap and/or shoe covers be worn in instances where "gross contamination" is anticipated (autopsies and orthopedic surgery are examples cited of gross contamination).

In terms of barrier performance standards, the rule mandates that PPE must not permit blood or other potentially infectious materials from passing through to reach "work clothes, street clothes, undergarments, skin, eyes, mouth or other mucous membranes" under normal use and for the duration of time that it is worn.

There is a major departure from language contained in the proposed version of the rule, which would have required that "fluid-resistant" PPE be used in circumstances where workers could be exposed to blood or infectious materials and "fluid-proof" PPE would have to be used if there was risk of saturation.

In its formal comment to OSHA, INDA noted concern about the lack of definitions for "fluid-proof" and "fluid-resistant" contained in the proposed rule. OSHA agreed that the terms were "confusing." So the rule makes it the employer's responsibility to ensure that the PPE offers adequate protection depending on the task being performed by the employee.

Not only must employers provide PPE that offers appropriate protection, they must also ensure that it is used properly, provided in appropriate sizes, readily accessible and removed by employees prior to leaving the work area.

In addition, employers must clean, launder and/or dispose of PPE at no cost to employees and must repair or replace PPE as needed to maintain its effectiveness.

Also, to ensure that it is used properly, employers must provide PPE training to their employees. Training is to provide information on the types, proper use, location, removal, handling, decontamination and disposal of PPE.

Finally, the rule specifies that any garment that is penetrated by blood or other potentially infectious material must be removed immediately or as soon as feasible. Also, when removed (either due to exposure or the end of the work period), PPE must be placed in an appropriately designated area or container for storage, washing, decontamination or disposal.

While the rule does not specify that either single-use or reusable PPE be provided by employers, there are several provisions contained in the regulation that could favor greater use of single-use products.

For instance, the rule states that contaminated wastes, such as single-use PPE that has been exposed to blood or body fluids, must be placed in closable containers that prevent leakage during handling, storage, transport or shipping. If these containers are reusable, they must be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately (or as soon as feasible) upon visible contamination.

Beyond this, however, if the waste has been decontaminated it does not need to be labeled or color-coded.

Contaminated laundry, on the other hand, is to be "handled as little as possible with a minimum of agitation," according to the new rule.

Contaminated laundry must be bagged or otherwise placed in a container at the location it was used and must not be sorted or rinsed in its location of use. Also, very importantly, laundry workers who handle contaminated laundry must follow universal precautions.

Furthermore, contaminated laundry that is wet or otherwise poses a threat of leakage must be contained and transported in containers that prevent leakage and/or soak-through. If it is to be sent to a facility that does not utilize universal precautions, the laundry must be placed in color-coded containers (so-called "red bags").

The rule also specifically states that PPE must be cleaned, laundered or disposed of by the employer at no expense to the employee and that the employer may not allow employees to remove PPE from the work area.

This provision could prove to be a real advantage for nonwovens because it is currently a common practice (according to OSHA) for many laboratory and health care workers to take their protective clothing home and launder it themselves. This practice will no longer be acceptable and employers will have to take over laundering responsibilities. Faced for the first time with having to either launder or dispose of PPE themselves - instead of leaving the task up to their employees - more employers might chose disposal.

Furthermore, taken together, all the restrictions on PPE and employer responsibilities for assuring its effectiveness could benefit single-use products. Since nonwovens are designed for single-use, they could relieve employers of many performance concerns. Certain concerns also could linger if the employer elects to use reusables. These include: Has the PPE been properly cleaned and decontaminated? Was its barrier protection compromised in the cleaning/decontamination process? Is the laundry where it was sent using universal precautions?

Where to From Here?

As the provisions of this rule take effect, employers will become more aware of their increased responsibilities for assuring that the PPE they provide for their employees is: 1) adequate for the task at hand; 2) available in appropriate sizes; 3) clean, decontaminated and free of defects; and 4) laundered or disposed of properly.

Within the new regulation, however, there is nothing that will make employers aware of ways that single-use products can help improve their compliance with the rule while maximizing protection of their workers.

As has always been the case, the task of making employers see the benefit of single-use PPE products over reusables will be left to the marketers within the nonwovens industry. But this new regulation should make that task a little bit easier.

Peter Mayberry is the director of government affairs for INDA, Association of the Nonwoven Fabrics Industry. He works out of the Washington, DC offices of Keller & Heckman, INDA's legal counsel. This Capital Comments column appears monthly in NONWOVENS INDUSTRY.
COPYRIGHT 1992 Rodman Publications, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
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Title Annotation:clothing protection for medical workers exposed to infectious blood or other bodily fluids
Author:Mayberry, Peter
Publication:Nonwovens Industry
Date:Feb 1, 1992
Previous Article:Nonwovens fiber shipments continue to climb.
Next Article:Geotextiles - poised for further growth in the 1990's.

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