OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
May 13, 1986
Occupational Safety and
Health Administration
200 Constitution Ave. N.W.
Washington, D.C. 20210
Dear Sir,
Recently several of our operating room staff members have joined to form a committee to review policies and procedures in Bronson Methodist Hospital's operating suite. We are presently questioning the pre-operative scrubbing technique. Presently, our policy states all personnel entering, and/or assisting at the operative field must scrub hands and arms to the elbows for 10 minutes for the first scrub of the day, and 5 minutes between operative procedures the rest of the day, usually averaging 5-6 times a day. This procedure is being questioned as a waste of time, scrub brushes, scrub medium, and the, reason I write, possibly high iodine levels in the personnel. Since our most frequently used scrub medium is an iodine-based soap, we were hoping you could supply us with any information on the iodine levels in the personnel of such a situation. Any information you may have will help us greatly in reviewing our present policy.
Thank You.
Sincerely,
Peggy Weaver, S.T.
c/o Bronson Methodist Hospital
252 E. Level St.
Kalamazoo, Mich. 49007