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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 19, 2011
Ms. Terry Jo Gile
Safety Lady, LLC
3300 Magnolia Landing Ln.
North Fort Myers, FL 33917-7806
Dear Ms. Gile:
Thank you for your August 18, 2010, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. In your letter, you mentioned that technicians in your laboratory routinely wear gloves to protect their hands from potential contact with infectious materials during the initial setting up of patient specimens and when subculturing blood cultures. However, technicians do not typically wear gloves when reading and selecting microbiological growth for identification from incubated culture plates. This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any situation not delineated within your original correspondence. Your question has been paraphrased below, followed by our reply. We apologize for the delay in responding to your request.
Question: Are gloves required to be worn by a technologist when reading and subculturing bacterial culture plates, after the plates were incubated and the organisms have grown out?
Reply: In diagnostic laboratories such as the one described in your inquiry, OSHA requires administrative and work practice controls, as well as the use of barrier protection (e.g., gloves) whenever employees' tasks may result in contact with biological organisms. OSHA standards require employers to first determine whether such work is potentially hazardous, and then implement the appropriate controls to protect workers. These OSHA standards include, but are not limited to, 29 CFR Part 1910, Subpart I, Personal Protective Equipment, and 29 CFR 1910.1030, Bloodborne Pathogens.
A number of factors, including employee training, expertise/proficiency level of technologists, adherence to standard operating procedures, and use of good work practices, may play a role in determining whether a technologist would be likely to contact biological organisms when handling incubated plates. Since it is likely for the exterior surface of a culture plate (or other culture-media container) to become contaminated prior to incubation, it is advisable that contact precautions are practiced even after the plates have been incubated and the organisms have grown out. The use of gloves is therefore encouraged to augment good work practices while reading and subculturing plates.
This is consistent with various laboratory guidance documents which offer best-practice recommendations on the appropriate use of gloves in laboratory settings. One such document, the Clinical and Laboratory Standards Institute's publication, Protection of Laboratory Workers From Occupationally Acquired Infections; Approved Guideline - Third Edition, states, "[l]aboratory workers are advised to wear gloves when handling material or working in areas that may be contaminated with blood or potentially infectious material. In some cases contamination is not always visible." [emphasis added] In the U.S. Department of Health and Human Services' publication, Biosafety in Microbiological and Biomedical Laboratories, 5th Edition, 2009, it is stated, "[g]loves must be worn to protect hands from exposure to hazardous materials. Glove selection should be based on an appropriate risk assessment."
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 continue to consult OSHA's Web site at www.osha.gov. If you have any further questions, please feel free to contact our Office of Health Enforcement at 202-693-2190.
Thomas Galassi, Director
Directorate of Enforcement Programs