Do scrubs count as personal protective equipment (PPE)? This is a common question for our Compliance Advisers.
The short answer: no. The long answer is a little more complex.
Why is PPE Important?
Hazards come in many forms. Irritants can be environmental, chemical, radiological, or mechanical. When encountered through absorption, inhalation, or physical contact, hazards can cause injury or impair any body part’s function.
The Occupational Health and Safety Administration (OSHA) has put laws in place to keep employees safe from physical harm. One aspect of OSHA is PPE.
When your employees are exposed to hazards on the job, you are legally required to ensure that they are adequately protected. OSHA fines can run up to $13,260 per violation for first-time offenders. Repeat serious violations can cost a practice $132,598 per violation.
PPE Must have Sleeves
Most scrub tops have short sleeves. According to OSHA, PPE must cover the arms down to the wrists. This law is in place to protect medical professionals from aerosols. If an employee were to utilize scrubs as PPE, the scrub top must have long sleeves. Another option is to wear arm coverings.
Why are sleeves important? Suppose staff members wore only their scrubs with no lab jacket, disposable jacket, or arm coverings. Their arms would be exposed to aerosols from the handpiece, ultrasonic scaler, or air and water syringes.
Now imagine employees going to lunch in contaminated scrubs. Everyone at lunch would be exposed to potentially pathogenic microorganisms.
When to Remove PPE
Employees must remove their protective wear whenever they leave a clinical area, and change them whenever they are visibly soiled. For scrubs to count as PPE, employees would have to change them more than if they wore medical gowns over their scrubs.
Employees Cannot Launder PPE
If a practice wants to consider scrubs as PPE, then OSHA prohibits employees from taking them home to launder. They must be laundered on-site or sent to a commercial laundry facility by the practice.
When the practice is a Partnership or a Sole Proprietorship rather than a Corporation or LLC, the Practice Owner is not considered an employee. The Practice Owner can take PPE home to launder.
Scrubs: Usually a Uniform
In most instances, medical employees wear their scrubs as a uniform and a lab jacket or medical gown when necessary.
If employees use scrubs as uniforms instead of PPE, OSHA does not have any oversight on laundering.
What is Better PPE than Scrubs?
OSHA recommends wearing lab jackets or gowns. These must be worn anytime an employee will be exposed to aerosols or liquid splatter of potentially infectious material.
In addition to lab jackets or gowns, other examples of PPE include:
For OSHA’s guidance on what PPE dental employees should wear during the COVID-19 pandemic, check out our blog.
Written Policies for PPE
Each dental facility should have a written policy on proper training and adequate PPE selection for employees.
Reach OSHA Compliance with Smart Training
If you want an easy employee training solution for PPE in dental offices, Smart Training’s Bloodborne Pathogens, Sharps and Office Safety, What’s Required for OSHA training module can help. At course completion, employees will be able to properly select and use PPE.
OSHA compliance isn’t an option—Smart Training makes it painless.