[Histonet] Are Gloves a CAP regulation?

Sat Mar 19 18:39:08 CST 2005

Long explanation, so if not interested in what CAP and OSHA say about
gloves, BBP and fixed/processed tissues, delete immediately.

Everything copied directly from a website is in quotes. My comments are not.

I went to the CAP Laboratory General checklist - www.cap.org

"GEN.72550             Phase II N/A   YES   NO
Is appropriate personal protective equipment (gloves, gowns, masks and eye
protectors, etc.) provided and maintained in a sanitary and reliable
condition in all technical work areas in which blood and body substances are
handled and in circumstances during which exposure is likely to occur?

NOTE:  If respiratory protection is needed because of potential exposure to
an infectious agent by aerosol or droplet, personnel should use either a
properly fit-tested NIOSH-approved filter respirator (N-95 or higher) or a
powered air-purifying respirator (PAPRS) equipped with high efficiency
particulate air (HEPA) filters.  Accurate fit testing is a key component of
effective respirator use.
COMMENTARY: N/A

REFERENCES: 1) Centers for Disease Control. Guidelines for prevention of
transmission of human immunodeficiency virus and hepatitis B virus to
health-care and public-safety workers. MMWR. 1989:38(suppl S-6):1-37;  2)
Krienitz DR. Safety education in the laboratory. Lab Med. 1996;27:823-827;
3) Occupational Safety and Health Administration. Toxic and hazardous
substances. Bloodborne pathogens. Washington, DC: US Government Printing
Office, 1999(Jul 1): [29CFR1910.1030];  4) Prinz Luebbert P. Q&A. Wearing
laboratory coats during break. Lab Med. 1999;30:710;  5) NCCLS. Protection
of laboratory workers from occupationally acquired infections; approved
guideline M29-A2. Wayne, PA: NCCLS, 2002. "

Notice it refers to OSHA 29CFR1910.1030 - Bloodborne pathogens. So I went to
the OSHA website
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id
=10051

"Occupational Exposure means reasonably anticipated skin, eye, mucous
membrane, or parenteral contact with blood or other potentially infectious
materials that may result from the performance of an employee's duties."

"Other Potentially Infectious Materials means (1) The following human body
fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid,
pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva
in dental procedures, any body fluid that is visibly contaminated with
blood, and all body fluids in situations where it is difficult or impossible
to differentiate between body fluids; (2) Any unfixed tissue or organ (other
than intact skin) from a human (living or dead); and (3) HIV-containing cell
or tissue cultures, organ cultures, and HIV- or HBV-containing culture
medium or other solutions; and blood, organs, or other tissues from
experimental animals infected with HIV or HBV."

"Parenteral means piercing mucous membranes or the skin barrier through such
events as needlesticks, human bites, cuts, and abrasions."

"Personal Protective Equipment is specialized clothing or equipment worn by
an employee for protection against a hazard. General work clothes (e.g.,
uniforms, pants, shirts or blouses) not intended to function as protection
against a hazard are not considered to be personal protective equipment."

So - my interpretation = infectious material that pertains to Histology
would be #2 - UNFIXED tissues or organs. So gloves should be worn when using
a cryostat, working with fresh unfixed tissue, for example.

Continuing -

"General. Universal precautions shall be observed to prevent contact with
blood or other potentially infectious materials. Under circumstances in
which differentiation between body fluid types is difficult or impossible,
all body fluids shall be considered potentially infectious materials."

Also -

"Engineering and work practice controls shall be used to eliminate or
minimize employee exposure. Where occupational exposure remains after
institution of these controls, personal protective equipment shall also be
used."

Concerning PPEs -

"Provision. 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."

"Gloves. Gloves shall be worn when it can be reasonably anticipated that the
employee may have hand contact with blood, other potentially infectious
materials, mucous membranes, and non-intact skin; when performing vascular
access procedures except as specified in paragraph (d)(3)(ix)(D); and when
handling or touching contaminated items or surfaces."

My interpretation - Universal precautions (which includes using gloves) are
necessary when there is the potential for exposure to infectious material.
If tissue is well fixed and processed, there is no need for gloves. In the
case of something like prions, which are not inactivated with
fixation/processing, then gloves might be a good idea when
embedding/sectioning brain (though as someone else pointed out, you probably
can only catch it if you eat the fixed/processed brain tissue, not from
touching it). If you push the tissue flat in the mold with the forceps
(i.e., you are not touching the tissue), there is no need for gloves. People
can be taught to not touch the tissue (engineering controls).

Some of my students wear gloves while embedding, some don't. (I tell them
they don't have to wear them, that it is not a regulation, fixation kills
microorganisms, that there is no documented exposure from embedding.) I
don't wear gloves, so they aren't learning it from me. But some of our
histotechs do, some don't.  Those students and techs who do wear gloves fall
into one of three categories of reasons: 1) they don't like the feel of the
paraffin on their fingers, especially when it starts to solidify, 2) their
fingers are sensitive to the temperature of the paraffin and they don't want
to wait until they develop the histotech's ability to handle 60 degree C.
paraffin, or 3) they still have a fear of "catching something", even after
lectures on fixation and processing.

Some Histonetter did raise a point that, since it is not an OSHA
requirement, does the institution have to pay for the gloves? OSHA does say
the employer must provide free gloves if there is a risk on occupational
exposure. OSHA doesn't say that the employer has to provide PPE if it is not
a requirement. That would be up to the employer as to whether they want to
pay for them or not. But, in my opinion, if we are talking about 1 pair of
gloves a day for a histotech to embed, and they are a good employee that you
don't want to lose, and it makes them feel "safer", and by giving them the
gloves, they will continue to work for you, I think the employer can afford
the gloves. Cheaper than having to find a new histotech, or train a new
histotech. (In my humble opinion.)

Peggy A. Wenk, HTL(ASCP)SLS
William Beaumont Hospital
Royal Oak, MI 48073

----- Original Message -----
From: <Heather.A.Harper <@t> pcola.med.navy.mil>
To: <histonet <@t> lists.utsouthwestern.edu>
Sent: Wednesday, March 16, 2005 8:10 AM
Subject: [Histonet] Are Gloves a CAP regulation?

>   Since I work at a military facility, I have notice that all the military
> histo techs wear gloves to embed and cut. I went to school and we never
did
> this. When CAP came last year, my co-worker insisted that this was a CAP
> regulation. Does anybody know if this is a CAP regulation, because this is
> news to me and I was never taught in school to wear gloves to embed or to
> cut. Thank you.
>
>
>
> Heather A. Harper
>
> Supervisor of Histology/Morgue
>
> Naval Hospital of Pensacola, FL
>
> _______________________________________________
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