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QUESTION: I just started at a new dental office in a front office position. When I asked if there was a dress code, I was told I could not wear open-toed shoes. I understand this policy, so I purchased three pairs of closed-toe shoes. I went to work in the new shoes, but I wore cropped pants. I was told that if I wore cropped pants, I would have to wear nylons or tights under my pants. The reasoning was that if I happened to walk by or into a dental operatory, I could possibly get something splashed on my partially bare legs. Is this an OSHA rule? I was told it is. I find it hard to believe that nylons or tights would protect my legs from any splash.
ANSWER FROM KAREN DAW, MBA, CECM, The OSHA Lady:
I think it’s great that your employer is concerned about your safety. Clothing as Personal Protective Equipment (PPE) in a dental setting is a topic that comes up often during my presentations. It may be helpful to know the Occupational Safety and Health Administration (OSHA) has charged employers with identifying hazards in the workplace and taking action to protect employees from those hazards. As you pointed out, in a dental setting this can include exposure to blood and bodily fluids.
Specifically, OSHA’s bloodborne pathogens standard (BBP) applies to employees with reasonably anticipated contact with blood or other potentially infectious materials (OPIM) that may result from the performance of their job. Those in clinical roles can expect that the likelihood of exposure is routine. Therefore, in addition to engineering and work practice controls, the employer must provide PPE to protect health-care workers.
Appropriate PPE must protect skin, eyes, mouth, and other mucous membranes, and work or street clothes (i.e., scrubs or clothing worn from home). Therefore, eyewear, masks, gloves, and scrub jackets or lab coats are commonly used. Regarding outerwear, the authors of From Policy to Practice: OSAP’s Guide to the Guidelines state that scrub jackets or lab coats should be long-sleeved, high-collared, and cover the knees when seated. If an item is designated for use as PPE, the employer is responsible for providing and maintaining the PPE and must ensure that the employee removes it before leaving the work area.
In summary, the employer decides what PPE is required in the workplace. PPE will be considered appropriate only if it prevents blood and OPIM from reaching the employee's work or street clothes, undergarments, skin, eyes, mouth, or other mucous membranes. If leg exposure to pathogens is a concern in the practice, hosiery and leggings may not be appropriate protection. While it’s unlikely your role at the front desk would place you in contact with blood or bodily fluids as part of your regular job duties, ultimately the employer must decide what PPE and dress code is best for the practice. I hope this helps explain OSHA’s role in this discussion.
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