Does OSHA conflict with the CDC on hand rubs?

To improve hand hygiene among health care workers, the Centers for Disease Control and Prevention (CDC) recommends the use of alcohol-based hand sanitizers. Health care workers only need to use the traditional soap and water if their hands are visibly soiled, according to the CDC.

The Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogen Standard adds a caveat, however. OSHA requires employees to wash their hands with soap and water if they have had "occupational exposure to blood or other potentially infectious materials."

"OSHA interprets this to mean that when an employee is removing gloves and has had contact, meaning occupational exposure to blood or other potentially infectious materials [OPIM], hands must be washed with an appropriate soap and running water," wrote Richard E. Fairfax, director of the Directorate of Enforcement Programs, in an interpretation letter.

"If a sink is not readily accessible (e.g., in the field) for instances where there has been occupational exposure, hands may be decontaminated with a hand cleanser or towelette, but must be washed with soap and running water as soon as feasible. If there has been no occupational exposure to blood or OPIM, antiseptic hand cleansers may be used as an appropriate hand-washing practice," he added

Gloves are not impervious, according to an OSHA industrial hygienist. Even if no contamination is visible after removing the gloves, soap and water still should be used, Fairfax stated.