Protecting Against Bloodborne Pathogens

When it comes to protecting against bloodborne pathogens, there are two commonly asked questions:

(1) Regarding bloodborne pathogens, can I use a hand sanitizing gel instead of soap and running water for hand washing?

(2) How close do hand washing facilities need to be to the work area for bloodborne pathogen work?

These are good questions. It would make sense that hand sanitizing gels would be an adequate substitute for soap and running water. After all, the statements on most labels state they kill more than 99.99% of germs. But, is that actually the case?

Let’s take a closer look at OSHA, Cal OSHA, and WA DOSH (for other states – check your local listings). OSHA is the Federal Government’s Occupational Safety and Health Administration and promulgates health and safety rules for the USA. OSHA has authorized some states to enforce their own health and safety rules as long as they are at least as stringent as OSHA. Two of these states are California (Cal OSHA) and Washington (DOSH). Each of these agencies has a Bloodborne Pathogen Standard in their regulations. OSHA’s can be found at 29 CFR 1910.1030. Cal OSHA’s can be found at 8 CCR 5913. Washington DOSH can be found at WAC 296-823.

If your facility is engaged in certain practices with certain infectious organisms, all three agencies say your work area shall contain a sink for hand washing. Note the variation in the type of organism and type of facility from agency to agency. So if you fall under these categories, this is pretty cut and dried.

OSHA 29 CFR, 1910.1030:

 1910.1030(e)(4)

HIV and HBV production facilities shall meet the following criteria:

1910.1030(e)(4)(iii)

Each work area shall contain a sink for washing hands and a readily available eyewash facility. The sink shall be foot, elbow or automatically operated and shall be located near the exit door of the work area.

Cal OSHA 8 CCR, 5193(e):

(4) HIV, HBV and HCV production facilities shall meet the following criteria:

 (C) Each work area shall contain a sink for washing hands and a readily available eyewash facility. The sink shall be foot, elbow or automatically operated and shall be located near the exit door of the work area.

DOSH WAC 296-823-180

Additional requirements for HIV and HBV research laboratories and production facilities.

WAC 296-823-18050

Furnish a sink for washing hands and a readily available eyewash facility.

You must make sure each work area contains a sink for hand washing and an eyewash facility is readily available. For HIV and HBV production facilities, the sink must be operated automatically or by foot or elbow and must be located near the exit door of the work area.

But what if you aren’t engaged in the production and/or research of HIV, HBV or HCV? The three agencies also address hand washing separately under work practice controls and define hand washing facilities the same: a facility providing an adequate supply of running potable water, soap and single-use towels or air-drying machines. And…there is an allowance if hand washing facilities are not feasible. We will take a look at what “feasible” might mean in a moment.

The language on this topic is very similar if not the same for OSHA, CalOSHA, and DOSH.

OSHA 29 CFR, 1910.1030 and CalOSHA 8 CCR, 5193(d)(3) both state the following:

Employers shall provide handwashing facilities which are readily accessible to employees.

When a provision for hand washing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes. When antiseptic hand cleansers or towelettes are used, hands shall be washed with soap and running water as soon as feasible.

Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment.

Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

 DOSH WAC 296-823-140 language is similar with the same intent to control employee exposure.

WAC 296-823-14030

Make sure employees clean their hands.

(1) You must provide hand washing facilities that are readily accessible to employees, wherever feasible. If hand washing facilities are not feasible, provide either one of the following:

(a) Antiseptic towelettes;

(b) Antiseptic hand rub product along with clean cloth/paper towels.

(2) You must make sure employees clean their hands as soon as feasible after removing gloves and whenever there is the potential for contact with blood or other potentially infectious materials (OPIM).

(3) You must make sure employees do one of the following:

(a) Wash with soap and water;

(b) Use an appropriate waterless antiseptic hand rub product or towelettes, provided there are no signs of visible contamination;

(c) Use an appropriate water-less antiseptic hand rub product or towelettes followed by washing with soap and water as soon as possible, when hands are visibly contaminated and hand washing facilities are not immediately available.

Note: An appropriate water-less antiseptic hand rub product is one that contains a 60-95% alcohol solution (isopropanol or ethanol.)

So, do you think it is ‘feasible’ for hand washing facilities to be at your facility? As luck would have it, several letters have already been written to OSHA asking questions about hand washing facilities. They can be found here:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24389

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22808

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20620

As usual, it is not always black and white when it comes to safety regulations. The first interpretation letter seems to suggest that sinks would not be readily accessible if the work area was ‘in the field’, and in this case, sanitizing gels would be allowed as long as hands were washed with soap and water as soon as feasible. The second interpretation letter seems to suggest that readily accessible means that you don’t have to walk through several doors/rooms/hallways (thereby increasing the spread of contamination) in order to reach the hand washing facilities. The third interpretation letter seems to suggest that sanitizing gels would be okay where running water was not feasible such as for ambulance crews or firefighters, as long as hands were washed as soon as feasible. So, my take away on this…if your facility has plumbing, the work area should have running water and soap provided in the work area. Hand sanitizing gels would be in addition to the running water and soap.

Of course, there are many ways to read the interpretation letters, and this is my interpretation of the interpretation letters. Let me know if yours are different.