Question:
Does OSHA regulate scrubs as PPE, and do they have jurisdiction over scrubs worn in public spaces?
Answer:
Scrubs are not considered PPE; they are generally worn in the capacity of a "uniform" or "street clothes". They are not expected to come into contact with blood or other potentially infectious materials because other PPE, such as a gown, should be used when performing activities with a risk of contamination. While concern about scrubs being contaminated is understandable, OSHA has not found this to exceed the action level. For these reasons, scrubs do not fall under the BBP standard requirement for contaminated laundry.
You are also not required to launder on-site, but you'll need to utilize a laundry service if you don't. The Bloodborne Pathogen Standard includes handling and transportation rules for contaminated laundry.
Please reference Questions 2, 3, and 6 from this letter of interpretation from OSHA. (Letters of interpretation are considered legal guidance.)
For more information, see below.
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Understanding OSHA’s Regulations on Scrubs and PPE: What Employers Need to Know
In healthcare settings, scrubs are often seen as a necessary uniform for professionals. However, there's some confusion about whether scrubs qualify as personal protective equipment (PPE) and if they are subject to OSHA regulations. In this blog post, we’ll explore what scrubs are, their role in healthcare environments, and what OSHA has to say about laundering and handling them.
Are Scrubs Considered PPE by OSHA?
Healthcare workers may think that scrubs are a form of PPE. This leads to some confusion, as they are often viewed as a necessary barrier against contamination. However, according to OSHA’s interpretation, scrubs are not considered PPE. Rather, they are regarded as a type of uniform or "street clothes." PPE is designed to protect workers from exposure to bloodborne pathogens (BBPs) and other hazardous materials, but scrubs are not expected to come into direct contact with blood or infectious materials.
When workers are performing tasks with potential for contamination, other PPE—such as gowns, gloves, or face shields—is required to minimize exposure. Scrubs themselves are not considered protective in this context, and they do not fall under the Bloodborne Pathogen (BBP) standard for contaminated laundry, as they aren't expected to come into direct contact with blood or other potentially infectious materials.
The Role of Laundering Scrubs: OSHA's Stance
One common concern in healthcare workplaces is the contamination of scrubs and the responsibility of employers to properly handle them. While it's understandable to worry about scrubs potentially being contaminated, OSHA has clarified that scrubs are not subject to the same laundering requirements as PPE under its Bloodborne Pathogen Standard.
According to a letter of interpretation from OSHA (dated February 27, 2009), scrubs do not exceed the action level for contamination, and therefore, they are not considered contaminated laundry requiring special handling under OSHA’s regulations. The letter also emphasizes that workers are not required to launder scrubs on-site.
If a healthcare facility does not have on-site laundry, the facility is allowed to use an external laundry service to handle scrubs. However, employers must ensure that laundry service providers follow proper procedures for handling potentially contaminated materials. For example, OSHA’s Bloodborne Pathogen Standard includes specific rules about how to handle, store, and transport contaminated laundry, so employers should ensure their laundry service providers comply with these regulations.
Key Takeaways from OSHA’s 2009 Interpretation
- Scrubs Are Not PPE: Scrubs are not considered personal protective equipment under OSHA regulations because they are not designed to protect workers from direct contact with blood or other infectious materials.
- Laundering Scrubs: Employers are not required to launder scrubs on-site, but if they do not have on-site laundry, they must arrange for a professional laundry service. The laundry service must follow OSHA's handling and transportation guidelines for contaminated laundry.
- Bloodborne Pathogen Standard Does Not Apply to Scrubs: The Bloodborne Pathogen Standard does not require scrubs to be treated as contaminated laundry unless they have come into contact with blood or other infectious materials, which is rare for standard tasks in most healthcare settings.
For more detailed information, you can refer to the full letter of interpretation from OSHA.
Does OSHA Have Jurisdiction Over Scrubs in Public Facilities?
A common question is whether OSHA regulates scrubs in public facilities, such as when healthcare workers wear them outside of work. OSHA does not regulate the use of scrubs in public spaces, as they are not considered PPE unless there is a specific risk of contamination. The responsibility lies with employers to ensure scrubs are properly handled and maintained within the workplace setting, and the concern about scrubs worn in public spaces is not a matter for OSHA jurisdiction.
Conclusion
While scrubs are commonly worn in healthcare settings, they are not considered PPE under OSHA regulations. As such, employers are not required to treat them as contaminated laundry unless they have come into direct contact with blood or infectious materials. If your workplace does not have on-site laundry facilities, you can use an external service, but make sure they comply with OSHA’s Bloodborne Pathogen Standard regarding the handling and transportation of contaminated laundry.
By understanding OSHA's stance on scrubs and PPE, employers can ensure they are meeting the necessary regulations while maintaining a safe and hygienic work environment.
