Addressing management issues

May 1, 2010
Gloves needed for phlebotomy?

Q What is the policy regarding wearing gloves during phlebotomy? I have a co-worker who often does not wear gloves despite the supervisor’s instructions to always wear gloves when drawing blood. Are gloves mandatory?

A On Dec. 6, 1990, the Occupational Safety and Health Administration (OSHA) published the Bloodborne Pathogen Standard that revolutionized the way we do business in the clinical laboratory. Some things were very straightforward, however, the use of gloves — when and by whom — still remains controversial.
OSHA specifically states in the compliance document 2-2.69, which is used by its inspectors to determine if a violation exists, that “the exemption regarding the use of gloves during phlebotomy procedures in paragraph (d)(3)(ix)(D) only applies to employees of volunteer-donor blood-collection centers, and does not apply to phlebotomy conducted in other settings such as plasmapheresis centers or hospitals. Everyone dealing with blood and body fluids — including phlebotomists — must wear gloves at all times.”
OSHA also requires that gloves must be provided by the employer in appropriate sizes, and no part of the glove must be removed (e.g., to palpate the vein) during the phlebotomy procedure.

—Terry Jo Gile,
The Safety Lady
North Fort Myers, FL

A OSHA clearly mandates glove use for all venous-access procedures, including fingersticks and venipunctures. Employees caught not using them subject the facility to fines and citations. Therefore, your supervisor is protecting not only your co-worker from an exposure but also protecting the facility from the consequences of an OSHA violation.

Those who choose to violate the
Bloodborne Pathogens Standard are at risk of acquiring any of
the 20 diseases known to be transmitted by blood exposure.
Therefore, your supervisor is trying to protect the tech from
herself. Not only that, but the tech is risking passing along
nosocomial infections to other patients. If the tech chooses to
violate facility policy on this, she is asking for dismissal.
Most hospitals are very strict about this.

Everyone on staff should be familiar with
OSHA’s Bloodborne Pathogens Standard. Ask your co-worker to
review the passage in Section 1910.1030(d)(3)(ix) at

J. Ernst, MT(ASCP)

Center for Phlebotomy Education
Corydon, IL

A OSHA requires all healthcare workers to wear gloves during phlebotomy. This is not an option! The intent is to wear two gloves, not just one, and to leave them intact. Popping off the fingertip to better feel the vein is not allowed. The regulations are as follows:

Gloves shall be worn when it can be reasonably anticipated that
the employee may have hand contact with blood, other potentially
infectious materials, mucous membranes, and non-intact skin;
when performing vascular access procedures except as specified
in paragraph (d)(3)(ix)(D); and when handling or touching
contaminated items or surfaces.

Disposable (single-use) gloves, such as surgical or examination
gloves, shall be replaced as soon as practical when contaminated
or as soon as feasible if they are torn, punctured, or when
their ability to function as a barrier is compromised.

There is one exception in OSHA’s
Bloodborne Pathogen Standard [1910.1030(d)(3)(ix)(D)]:

If an employer in a volunteer
blood-donation center judges that routine gloving for all
phlebotomies is not necessary then the employer shall:

  • periodically re-evaluate this policy;
  • make gloves available to all employees
    who wish to use them for phlebotomy; and
  • not discourage the use of gloves for

The employer in this case shall require
that gloves be used for phlebotomy in the following

  • when the employee has cuts, scratches,
    or other breaks in his skin;
  • when the employee judges that hand
    contamination with blood may occur, for example, when
    performing phlebotomy on an uncooperative source individual;
  • when the employee is receiving training
    in phlebotomy.

Bachman, BS MT(ASCP), CLC(AMT)
Tennessee Medical Laboratory Supervisor
Partner and Compliance Department Director
Knoxille, TN

Wearing gloves and defacing the product by tearing
off the fingertip does not qualify as “wearing” personal

A All laboratory
accrediting agencies, such as College of American Pathologists
and The Joint Commission, mandate wearing of gloves when
performing venipunctures on patients. It is also likely that all
state health departments require this as well (PA does).

So, there is absolutely no option here:
gloves must be worn. This tech is putting himself at risk, and
he is putting patients and the hospital at risk, as well.
Wearing gloves during phlebotomy is for the protection of the
healthcare worker from contamination from patients.

If you are friends with this tech, try to
influence his behavior. Let him know that you worry about the
potential for exposure when he fails to wear gloves. Explain
that wearing gloves is not merely the supervisor’s rule but an
accreditation regulation, so your facility can be cited for
being in violation of The Joint Commission regulations, which
puts everyone’s jobs at risk, not just his.

If this tech refuses to become compliant
with the glove-wearing policy, your supervisor should initiate
disciplinary procedures.

Finding qualified techs can be difficult in many areas of the country, but everyone can be replaced. And no matter how bad things might be without this tech, it is worse to let him continue being non-compliant.

Bailey, MT(ASCP), CPC
Work Unit Leader, Pathology
Penn State Milton S. Hershey Medical Center
Hershey, PA

Bottom line:

The Federal rules of the Bloodborne
Pathogens Standard requires that gloves be worn at all times
during a venipuncture or capillary stick procedure. Wearing
gloves and defacing the product by tearing off the fingertip
does not qualify as “wearing”personal protection.

The individual not wearing gloves during
a procedure that requires gloves should immediately be counseled
and have disciplinary actions taken against him — up to and
including termination, depending on your facility’s policy. If
your facility does not have such a policy, it should make one.

MLO’s “Management Q & A” provides practical, up-to-date solutions to readers’ management issues from a panel of laboratory management experts. Readers may send questions to Anne Pontius at [email protected]. Unless otherwise noted as “confi dential” by readers, all queries will be considered for publication without further notice to them. Names, institution, city, and state will be removed before publication.

Anne Pontius is a senior medical practice consultant with State Volunteer Mutual Insurance Co. in Brentwood, TN, and president of CLMA. Send questions to Ms. Pontius at
[email protected].

Published: May, 2010