Are Scrubs Considered PPE?

That’s a question our Compliance Advisers are asked every week in the field. The short answer is “NO.” The long answer is a little more complex. Most scrub tops have short sleeves, which, for all practical purposes, makes them ill-suited for PPE, as PPE must cover the arms down to the wrists, to protect them from aerosols.

​So, if someone were to utilize scrubs for PPE, the scrub top would have to have long sleeves or they would have to also wear arm coverings as well. In addition, if someone wore scrubs as PPE, they would have to change them whenever visibly soiled and could not wear them outside of clinical areas. In most instances, dental office teams wear scrubs as their office “uniform,” and wear a lab jacket when necessary...

​Hazards come in many forms. They can be environmental, chemical, radiological, or mechanical irritants that when encountered in a certain way makes them capable of causing injury or impairment in the function of any part of the body through absorption, inhalation, or physical contact. The question of laundering scrubs often arises. If scrubs do not function as PPE but as a uniform, then OSHA does not have oversight on laundering. If scrubs function as PPE, then the employer is in violation of the BBP standard by having employees clean, launder, and maintain scrubs on their own (1910.1030(d)(3)(iv)). Lab jackets are PPE, and they are required to be laundered by the employer. If staff members wear only their scrubs as PPE and no lab jacket or disposable jacket, they are exposing their arms to aerosols from the handpiece, ultrasonic scaler, or air/water syringes. Now imagine someone going to lunch in contaminated scrubs. They are exposing everyone at lunch, either in an employee lounge area or restaurant, to potentially pathogenic microorganisms. Each dental facility should have a written policy on proper training and adequate PPE selection for employees.

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