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 https://www.osha.gov.

May 6, 1992

Heber Simmons, Jr., D.D.S.
1855 Crane Ridge
Jackson, Mississippi 39216

Dear Dr. Simmons:

Thank you for your letter of March 19, concerning our March 17, meeting with you and representatives of the American Dental Association to discuss some of your concerns regarding the Final Standard for Occupational Exposure to Bloodborne Pathogens. In that meeting, you indicated that you would prefer to wear a regular long-sleeved shirt rather than a clinic jacket or a lab coat when you treat your pediatric patients. It was your opinion that children would be less afraid initially if the dentist wears a regular shirt.

The standard states the requirements for personal protective clothing in performance language. Paragraph (d)(3)(i) states:

When there is occupational exposure, the employer shall provide, at no cost to the employee, APPROPRIATE personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "APPROPRIATE" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

It is the employer's responsibility to evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective clothing in accordance with paragraph (d)(3)(i) of the standard. In general, OSHA would expect the employer to select traditional protective clothing, such as clinic jackets, lab coats, or uniforms.

This type of clothing is designed to serve as a barrier to strike-through and would protect underlying garments or skin. We would allow the use of other garments, such as a regular long- sleeved shirt, when it clearly meets the test of appropriateness described in the standard and quoted above. For example, when the pediatric dentist greets the child and performs the initial examination, the dentist may choose to wear a long-sleeved shirt. A long-sleeved shirt may also be worn for other procedures, as long as it serves as a barrier and prevents contamination of underlying skin or garments. However, it is unlikely that a long-sleeved shirt would be adequate for oral surgery. Procedures that would result in strike-through if a regular shirt were worn would require traditional protective clothing, for example, a clinic jacket.

Garments used as protective clothing, including long-sleeved shirts, are subject to the requirements specified in paragraph (d)(3) of the final standard, including requirements for removal, cleaning, repair and replacement.

We hope that we have answered your question.


Dorothy L. Strunk
Acting Assistant Secretary