CDC - "Draft Guideline for Hand Hygiene in Healthcare Settings"

a letter written by Maureen Best
President, American Biological Safety Association
7 December 2001

HH Guide
Division of Health Care Promotion
Centers for Disease Control and Prevention
Mailstop E-68
1600 Clifton Road, NE
Atlanta, GA 30333

December 7, 2001

Dear Sirs,
The American Biological Safety Association (ABSA) is an organization of biological safety practitioners who work in a variety of academic, governmental, and industrial work environments. We have many members in the United States, Canada, and in other countries. We are recognized as a leading authority in the field of biological safety.

We have reviewed your document entitled, " Draft Guideline for Hand Hygiene in Healthcare Settings". Please consider the comments which follow:

Health care workers wear disposable gloves as barrier protection against bloodborne pathogens as per CDC guidelines and OSHA regulations. There are standards that need to be considered in the selection of disposable gloves used in these settings. First, the Food and Drug Administration (FDA) requires that gloves worn in a health care setting for protection against bloodborne pathogens need to be registered with the FDA as medical devices. As such, the manufacturer should have received a 510(k) number from the FDA for the gloves. Second, latex is the type of material most frequently used in disposable gloves, because latex has been found to provide the best barrier against bloodborne pathogens. Latex may also be an allergen to some health care workers, and health care workers have a greater incidence of latex allergy than the general population (8-12 % in health care workers versus 1-6% in the general population). The use of powder free, low protein gloves has been recommended for use by health care workers by the National Institute of Occupational Safety and Health (NIOSH). The American Society of Testing and Materials (ASTM) in ASTM D 3578-00a recommends that latex gloves should contain no more than 200 micrograms/decimeter squared of water extractable protein in order to be considered low protein.

The use of disposable gloves that meet these standards should be noted in your guide. The FDA requirements establish specific glove integrity adulteration rates that must not be exceeded. The use of gloves that do not meet these standards can result in greater penetration of bloodborne pathogens to a health care worker's hands. The ASTM standards establish maximum water extractable protein content for latex gloves. Latex is a water extractable protein. The use of gloves which do not meet this standard will likely have a higher latex content. The presence of such an allergen may sensitize the health care worker's skin and make it more susceptible to bloodborne pathogens that may penetrate the glove. Your guide acknowledges that any glove will not provide complete barrier protection against bloodborne pathogens due to possible access through small glove defects. Noting in your guide the need for disposable gloves to address these standards should help to reduce the bloodborne pathogens on the health care worker's hands and also leave them less susceptible to infections. This step will help to realize greater efficacy from the hand hygiene practices noted in your guide..

Lastly, petroleum based products can break down latex and affect the barrier integrity of latex gloves. The use of petroleum based hand lotions by health care employees could allow the penetration of more pathogens to employee hands through breaks in glove material. Your guide acknowledges this by recommending that the institution review the use of these products at the facility. However, it is also important for employees to be aware of this fact. The employees may use personal hand lotions independent of the ones standardized for use in the institution before they come to work or when they are at work or meal breaks. If they are aware of the potential consequences regarding the use of these personal products, then they will be more likely to use the products that the institution has selected.

Thank you for the opportunity to have provided input for a valuable resource. Sincerely,

Maureen Best
American Biological Safety Association

Maureen Best, CDC - "Draft Guideline for Hand Hygiene in Healthcare Settings", American Biological Safety Association (7 December 2001),

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