August 24, 1993

Geraldine L. Dettman, Ph.D President
Viro Research International, Inc.
22471 Aspan St.,
Suite 102
El Toro, CA 92630-1643

Dear Dr. Dettman:

This is in response to your letter of July 2, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens."

Specifically, you asked whether there is "an official opinion, position or policy for advice to health care and public safety workers, to avoid the use of mineral oil and/or petrolatum containing skin care products that may come in contact with latex gloves."

Although paragraph (d)(2)(ix) of the standard states that applying cosmetics is prohibited in work areas where there is a reasonable likelihood for occupational exposure, hand cream is not considered to be a cosmetic and is permitted. However, it should be noted that some petroleum-based creams can adversely affect glove integrity.

The standard provides that when there is occupational exposure, the employer shall provide "appropriate personal protective equipment." It also states that personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or to 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.

During the rulemaking process, it was brought to OSHA's attention that significant deterioration of latex gloves was noted when exposed to petroleum-based lubricants. (See 56 Federal Register 64119, December 6, 1991.) Therefore, if latex gloves are used, employees shall not apply petroleum-based, including mineral oilbased, skin care products. If appropriate, this information must also be transmitted to employees as part of their required training.

The State of California is one of the twenty-five states which administers its own safety and health program, which is overseen and monitored by Federal OSHA. State plan standards must be at least as effective as Federal OSHA standards, and the state may choose to promulgate and enforce requirements which are stricter than Federal OSHA's. You may therefore wish to contact the California State Plan regarding this issue as well. They may be reached at the following address and phone number:

Director California Department of Industrial Relations 455 Golden Gate Avenue, 4th Floor San Francisco, CA 94102 415-703-4590

We hope this information has been responsive to your concerns. Thank you for your interest in employee safety and health.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs




July 2, 1993

Office of Health Standards
Occupational Safety and Health Administration
200 Constitution Avenue, NW
Washington, DC 20210

Dear Madam or Sir:

We are writing following several informative conversations with personnel in your Philadelphia office. The most recent conversation was with Mr. Joe McFee and our Mr. John Marshall. Mr. McFee gave us permission to mention his name and provided your address.

We have been made aware of the concern for the integrity of latex gloves, such as those worn by healthcare and public safety workers, when there is contact with mineral or petrolatum containing skin creams or lotions. We understand this concern to be similar to the message on latex condom packages, warning that the use of lubricants containing mineral oil and/or petrolatum, may/will lead to the failure of the condom.

The purpose of our letter is to determine if there is an official opinion, position or policy for advice to healthcare and public safety workers, to avoid the use of mineral oil and/or petrolatum containing skin care products that may come in contact with latex gloves.

We would appreciate your comments on the use of mineral oil and/or petrolatum containing skin creams and lotions by employees who must follow the OSHA regulations, including the wearing of latex gloves.

Thank you for considering our request, we look forward to your reply.

Sincerely,



Geraldine L. Dettman, Ph.D.
President