The above antiseptic alternative is permitted as a temporary measure if an employer can demonstrate that soap and water are not a viable means of hand washing, such as for paramedics, firefighters or mobile blood collection personnel. First, it is not clear from your letter whether the employees in the scenario you are planning are engaged in the application of paints, coatings, herbicides or insecticides, or in other operations where contaminants may be harmful to employees. Please note that the requirements of this provision only apply if employees perform such activities.1 If employees engage in such activities, the employer must provide appropriate sanitary facilities. Although the standard does not adequately define “adequately,” it does state that “such facilities . be equipped to allow workers to remove harmful contaminants. Whether “a few cloths and a box of waterless hand cleaners” could meet the requirements of section 1926.51(f)(1) therefore depends on whether they “would permit employees to dispose of these substances.” Generally, the employer`s provision of waterless hand cleaner and towels or cloths is not sufficient to remove harmful contaminants. In the past, OSHA has reviewed data on whether wet towels or other waterless hand cleaners are sufficient to remove harmful contaminants and has found that these cleaners are not a sufficient substitute for soap and water. In 1987, OSHA issued a final rule for field remediation, 29 CFR1928.110. 2 Among other things, it requires all employers of 11 or more manual field workers to provide adequate handwashing facilities, including drinking water, soap and disposable towels. OSHA based its conclusion that waterless cleaners were not a sufficient substitute primarily on statements from a number of medical professionals. Some health experts have pointed out that packaged wet towels, unlike soap and water, do not prevent the spread of harmful bacteria, communicable diseases or pesticide poisoning.
3 In fact, some health experts have testified that wet towels increase the risk of infection, especially from pesticides.4 Finally, health professionals testified that the availability of drinking water on construction sites is important for treating or flushing eye or skin injuries caused by exposure to pesticides or other hazardous contaminants.5 OSHA then concluded that the current shortage of handwashing facilities is not due to a New Rule. This is because there has been an increased awareness among workers who are now demanding the handwashing facilities they have always been entitled to under the law. This is also due to increased enforcement by officials in some regions. So keep the following in mind, as this will help you choose handwashing stations now and in the future. (3) Appropriate drying devices (e.g. individual towels, ladies` towel service or electric hand dryer). Although § 1928.110 does not apply to your scenario, the rulebook of this standard states that the “washes” necessary to remove paints, coatings, herbicides, insecticides or other contaminants that may be harmful to construction workers would not be “appropriate” unless they contain soap and drinking water. For more information, please fax us to: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, Fax #202-693-1689. You may also contact us by mail at the office above, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in receiving correspondence by mail. Sincerely, Russell B.
Swanson, Director of the Construction Branch In short, handwashing facilities are not a new OSHA requirement, and when COVID-19 is over, the need will still be there. The awareness that the pandemic has raised on this issue could be one of the best outcomes of this difficult period. (b) Your handwashing facilities must be equipped with: All of the following requirements apply to handwashing facilities: The Occupational Safety and Health Administration (OSHA) Exposure to Bloodborne Pathogens Ordinance, 29 CFR 1910.1030, requires in sections (d)(2)(iii) and (v) that “employers shall provide adequate handwashing facilities for employees” and “ensure that employees are undressed after leaving to wash their hands immediately or as soon as possible gloves or other personal protective equipment”. In paragraph (d)(2)(iv), the standard allows for an alternative to the standard handwashing system: “If the provision of handwashing facilities is not possible, the employer shall provide either an appropriate antiseptic hand cleaner in conjunction with clean cloth or paper towels or antiseptic towels. If antiseptic hand cleaners or towels are used, hands should be washed with soap and running water as soon as possible. (d) You should not use antiseptic hand rubbing as a substitute for soap (or any other effective surfactant) and water. (2) Running water that meets the requirements of paragraph 112.44(a) for hand washing; and As you can see, the PSAI/ANSI standard requires more than OSHA requires – and that`s something to be pulled. It does not have the force of law. In 2020-2021, we will begin regular 5-year updates to ANSI/PSAI, which may increase handwashing requirements in ANSI/PSAI.
Overall, all OSHA standards currently have the force of law. Therefore, you should at least always be able to advertise the equipment and service levels listed in existing standards, which you can read in full on this page of the PSAI website. Before the COVID-19 emergency, portable plumbing companies were sometimes turned away by customers because OSHA standards have “exits” that make them think they don`t need to provide portable installations. These mainly apply to mobile teams that can easily drive to sanitary facilities – usually a group of workers who travel all day and can inspect the lines. It generally does not apply to construction sites where everyone is in the same place. In fact, existing OSHA rules explicitly state that in most cases, these are the requirements on construction sites. And where toilets are available, OSHA standards also require handwashing stations. Handwashing station suppliers are ramping up production of these devices and expect deliveries soon. Meanwhile, portable plumbing operators have been creative when it comes to building temporary stations and modifying existing equipment, and they are finding all sorts of ways to meet their customers` needs. (c) for the proper disposal of waste (e.g.
sewage and single-service used towels) associated with a hand wash, and take appropriate measures to prevent wastewater from a handwashing plant from contaminating covered products, food contact surfaces, areas used for a covered activity, agricultural water sources and agricultural water distribution systems with known or reasonably foreseeable hazards. Nebucid 880 can be accepted as an alternative handwashing technique and can certainly be used as a complementary cleanser after regular hand washing. However, where handwashing facilities are possible, OSHA expects employers to provide them and ensure their use. Although the day is still far away, it is certain that the supply of handwashing systems will ultimately be based on demand. A big question for operators buying more hand washes is, “Will I still need all these devices when COVID-19 is over?” July 20, 2005 James W. Banford, Jr. Commercial Director International Brotherhood of Boilermakers Local Lodge No. 13 2300 New Falls Road Newportville, PA 19056 Re: Construction Site Car Wash Requirements at 29 CFR 1926.51(f) (1) Dear Mr. Banford: This is in response to your letter dated February 1, 2005 to the Occupational Safety and Health Administration (OSHA) regarding the requirements of section 1926.51(f)(1). Unfortunately, we did not receive your letter until April 4, 2005; We apologize for the delay in responding. We have paraphrased your question as follows: Question: Does 29 CFR 1926.51(f)(1) require contractors to provide drinking water and hand soap? Would it be enough to provide “a few cloths and a can of waterless hand cleaner” instead? Answer: 29 CFR 1926.51(f)(1) states: OSHA requirements are set out in laws, standards, and regulations. Our interpretative letters explain these requirements and how they apply to particular circumstances, but they cannot create additional obligations for employers.
This letter represents OSHA`s interpretation of the requirements under discussion. Please note that our enforcement guidelines may be affected by changes to OSHA rules. We also update our guidelines from time to time in response to new information.