Skin exposure in healthcare work

Scope

While the healthcare industry is about providing medical care to patients, these employers must also protect their workers from serious, recognized hazards, such as skin exposures, when OSHA or a state-plan state has jurisdiction.

Regulatory citations

• 29 CFR 1904 — Recording and reporting occupational injuries and illnesses
• 29 CFR 1910.120 — Hazardous waste operations and emergency response
• 29 CFR 1910 Subpart I — Personal protective equipment
• 29 CFR 1910.141 — Sanitation
• 29 CFR 1910.1000 — Air contaminants
• 29 CFR 1910.1047 — Ethylene oxide
• 29 CFR 1910.1048 — Formaldehyde
• 29 CFR 1910.1096 — Ionizing radiation
• 29 CFR 1910.1030 — Bloodborne pathogens
• 29 CFR 1910.1200 — Hazard communication
• 29 CFR 1910.1450 — Occupational exposure to hazardous chemicals in laboratories

Key definitions

• Absorption: The process by which substances enter the human bloodstream through the skin.
• Contaminant: A substance that poisons or pollutes.
• Dermal: The skin or being related to the skin.
• Route of exposure: The path a substance takes to enter the human bloodstream or body. This may include absorption (through the skin), injection (through a puncture), or other routes of entry.

Summary of requirements

To protect healthcare workers from skin exposures, employers must:

• Furnish to each employee employment and a place of employment free from recognized hazards that cause or are likely to cause death or serious physical harm to workers.
• Provide and ensure the use of appropriate personal protective equipment (PPE) and protective clothing such as gowns that shield workers from skin contact with harmful agents.
• Establish a reasonable procedure for employees to report work-related skin diseases or disorders promptly and accurately. Inform employees of your procedure, that they have a right to report work-related injuries and illnesses, and that you are prohibited from discriminating against them for reporting.
• Meet the requirements of OSHA regulations, such as the ones listed above, if applicable.

Healthcare employers are recommended to also:

• Designate personnel to ensure healthcare worker safety and health.
• Establish an occupational exposure management plan to encourage workers to report skin exposures and to decontaminate and follow up with healthcare workers who report an exposure.
• Eliminate hazardous agents or substitute the hazardous agents with less hazardous ones, where feasible.
• Use engineering controls to prevent hazardous agents from contacting workers’ skin, such as by having workers use tools instead of their hands.
• Provide the use of barrier creams where PPE is not feasible.
• Urge workers to avoid touching the face, eyes, or mouth during any patient care and to limit touching surfaces and body fluids.
• Enforce the safe use and storage of sharps, scalpels, and other hazardous instruments to prevent cuts, lacerations, and punctures.
• Immediately clean and disinfect any potentially contaminated surfaces, equipment, or reusable PPE.
• Apply procedure control measures, such as routine decontamination procedures for workers who leave hazardous areas or good housekeeping methods to avoid the accumulation of contaminants on horizontal surfaces.
• Encourage workers to wash their hands with soap and to dry them thoroughly, after removing gloves.
• Call on workers to watch for and report signs of unhealthy skin conditions.
• Urge workers to change work clothes after using a hazardous agent.
• Provide training regarding skin exposures.
• Implement any other procedures, as they see fit, that protect workers and their skin from chemical, physical, and biological agents and mechanical trauma.