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Question |
This article addresses questions the Committee has received about using personal protective equipment (PPE) to stay safe when handling property and evidence that may be potentially hazardous. As the COVID-19 pandemic continues, the EMSC wants to provide a reminder about the importance of exposure control and the use of PPE in the management of property and evidence.
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Background |
According to the U.S. Occupational Safety and Health Administration (OSHA), PPE is defined as “equipment worn to minimize exposure to hazards that cause serious workplace injuries and illnesses.”
Types of PPE vary widely. The most commonly used PPE aims to provide protection to your:
- Eyes, with goggles, safety glasses, or face shields.
- Hands, with gloves made with appropriate materials for protection from chemicals, heat, electricity, biological material, or sharps (e.g., needles, blades, or pointed objects).
- Feet, with closed-toed shoes or protective booties.
- Skin and clothing, with lab coats/gowns, sleeve/arm guards, hair bonnets/bouffant caps, or beard covers.
- Lungs/respiration, with face masks, respirators, or face shields.
- Hearing, with earplugs or earmuffs.
OSHA standards require all employers to provide PPE in workplaces where staff are vulnerable to potential job-related injuries, illnesses, and fatalities. Organizations handling property and physical evidence are no exception. Personnel must wear PPE to protect themselves when handling drugs, bodily fluids, sharps, chemicals, or other hazardous materials.
Additionally, evidence handlers must wear appropriate PPE, not only to protect themselves, but also to protect evidence from damage or contamination by themselves or the surrounding environment. For example, PPE is used to prevent biological material containing DNA from being transferred from the examiner to the evidence during analysis or to avoid inadvertently damaging fingerprints on evidence.
Since property and evidence are typically packaged prior to submission, handlers may assume that PPE is not necessary. However, there are instances in which packaging alone is not sufficient to prevent hazardous exposure or contamination, leaving personnel vulnerable to illness or injury. Specifically, evidence which contains extremely hazardous materials such as fentanyl, fentanyl analogs, or other potent chemical/biological agents that can be aerosolized, can cause harm since even small quantities of a particular substance can potentially be found on the outside of packaging materials. A study conducted by NIST provides a visual representation of how drug particles can spread during forensic examination. Similarly, bloodborne pathogens can be transmitted via dried blood, which can also be aerosolized and potentially found in trace amounts outside of evidence packages.
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Problem |
Using PPE can be demanding for the wearer, as it may be more difficult to breathe, speak, and see. Often, the extra layers of protection can cause overheating or sweating. The natural human tendency is to adjust PPE so that it is more comfortable, which commonly means taking it off or touching contaminated hands to the areas of discomfort, increasing likelihood of transferring contaminants via contact or rendering the PPE itself useless. In order for PPE to be effective, it must be used correctly, and proper discipline must be maintained to avoid various forms of contact transfer. Without appropriate policies, procedures, and training for the correct donning, use, doffing, and maintenance, PPE will not protect staff or evidence.
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The Solution |
Appropriate administrative controls and work practices should supersede PPE to prevent hazardous exposures and contamination which can occur during property and evidence transport, sorting, staging, viewing, examination, release, and destruction. While it is the last line of defense to protect not only the handler, but also the property or evidence itself, the use of PPE alone is generally the least effective means of ensuring hazard prevention. Wearing PPE in combination with other controls is a must when handling property or evidence.
The National Institute for Occupational Safety and Health (NIOSH) recommends a “prevention through design” approach, which ranks hazardous control methods as follows:
- Elimination: Physical removal of hazards to the greatest extent possible.
- Substitution: Replacing hazards with less hazardous items when possible.
- Engineering Controls: Isolating people from hazards to reduce exposure to as few people as possible.
- Administrative Controls: Changing the way people work to reduce exposure to hazards.
- PPE: Protecting the worker using PPE, as a final resort, if exposure by any other means is not preventable.
Evidence handlers should apply this approach when identifying instances in which PPE is necessary. For example, reducing or eliminating the intake of non-evidentiary sharps (needles, blades, or pointed objects) into property and evidence rooms by properly disposing of these items at the time of collection. This policy would qualify as an elimination method since the potentially hazardous object never reaches the work environment. An example of an engineering control as outlined by the NIOSH approach would include strict limitations on personnel access to objects that may contain drugs, chemicals, or biological material that can be inhaled via aerosolization.
Other factors that contribute to the successful use of PPE include effective management, detailed and specific administrative policy, and effective training. These considerations are highlighted below:
1. Management
- Identify resources to guide administrators in elimination and control of hazardous exposures and contamination. See references listed in the best practices list.
- Obtain input from front line workers to assist in developing the appropriate solutions for controlling hazards and appropriate use of PPE.
- Identify the people responsible for adherence to policy and procedures. In many agencies, safety officers are assigned to assist in adherence to relevant policies and regulations regarding PPE usage.
- Work with supervisors to plan budgets for training and implementation.
- Frequently review safety policies and compliance, per OSHA guidance and/or relevant SOPs.
2. Administrative Policy
a. Consider incorporating important details in the organization’s safety manual.
- Explain the reasoning for using safety controls, including PPE.
- Include pertinent local, state, and federal public health guidelines.
- Detail appropriate use of PPE for the various scenarios encountered by the organization’s personnel.
- Detail the proper way to dispose of contaminated PPE items and describe in detail how to decontaminate non-disposable PPE items prior to re-use.
- Provide training specifications for equipment use and how the equipment is provided to staff.
- Detail how PPE use will be monitored.
b. Provide adequate PPE to staff and visitors.
- PPE should be disposable, when possible.
- Store PPE for ready use and easy access.
- Maintain sufficient quantities of PPE in appropriate sizes.
- Do not use PPE past its expiration date, if it has one. Ensure that expiration dates are clearly visible on outer packaging of PPE stockpile.
- If respirators are required, arrange for staff medical clearance, fit test, and specialized training and testing.
c. Ensure non-disposable PPE is decontaminated properly.
- Use professional cleaning services for non-disposable PPE clothing items (e.g., scrubs and lab coats).
- Maintain proper decontamination supplies and equipment, such as UV boxes, for items that must be reused (e.g., face shields, masks, respirators).
- Monitor the number of decontamination cycles and replace PPE items reaching their maximum cycle limits.
3. Effective Training
- Emphasize proper protocols for each scenario in which PPE is needed.
- Instruct staff on how to don PPE properly.
- PPE donning must take place in a clean area, prior to any possible exposure.
- The following PPE donning order follows CDC guidelines. Not all steps may be required due to the nature of the property or evidence to be handled.
- First, cover the torso (e.g., with a gown/lab coat);
- Second, cover footwear with booties;
- Next, cover mouth and nose with a mask or respirator;
- Then, cover hair and beard;
- Next, don a face shield or safety glasses;
- Finally, don gloves.
- Focus on proper glove use, including avoiding self-exposure due to touching the face or adjusting PPE after touching potentially contaminated items.
- Stress the need to change gloves frequently to avoid cross contamination and to replace those that have been damaged.
- Highlight how contaminated items (e.g., gloves, evidence) can contaminate clean items (e.g., pens, notes, work surfaces, evidence) during evidence collection, analysis, and during any evidence correction processes (e.g., impound error reviews, repackaging).
- Teach staff to doff PPE properly.
- PPE removal must take place in an area that will not cause contamination of clean areas or other items.
- If there are signs of contaminated PPE or other items (e.g., clothing), remove those items first, before removing uncontaminated PPE. If necessary, to contain or decrease cross-contamination, cut contaminated PPE off the wearer.
- If there is no visible sign of contamination, remove PPE in the following order:
- First, remove gloves;
- Then, remove eye protection;
- Next, remove the gown or lab coat, and;
- Finally, remove the mask.
- Clean hands by washing or using ethanol-based hand sanitizer immediately after doffing PPE.
- Dispose of used/contaminated PPE in proper containers, adequately marked as contaminated, and suitable for used PPE disposal.
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Hazard Elimination and Control, Including Personal Protective Equipment Best Practices |
Useful resources related to PPE standards and recommendations, including the proper sequence for donning and doffing PPE, include:
Hazard Prevention and Control, Occupational Safety and Health Administration (OSHA)
This site describes action items that management should follow to effectively control and prevent hazards, including an overview of the hierarchy of controls.
Personal Protective Equipment, Occupational Safety and Health Administration (OSHA)
This site provides an overview of PPE and includes links to OSHA PPE standards and recommendations.
PPE Sequence, Centers for Disease Control and Prevention (CDC)
This publication offers guidelines for the sequence for donning and doffing PPE.
Personal Protective Equipment, The National Institute for Occupational Safety and Health (NIOSH)
This site provides information on PPE and links to NIOSH’s ongoing research into protective equipment.
Evaluation of Occupational Exposures to Illicit Drugs at Forensic Sciences Laboratories
This study evaluates the potential occupational exposure to illicit drugs among employees working in controlled substances laboratories and provides recommendations for eliminating and controlling those exposures.
Exposure to fentanyl is a significant concern in the property and evidence management community. The following references provide additional information specific to fentanyl handling and potential exposure:
Community of Practice Newsletter: Volume 1, Issue 1
This newsletter issue addresses best practices for handling property and evidence with suspected or known fentanyl contamination.
Preventing Emergency Responders’ Exposures to Illicit Drugs, Including Fentanyl
This documentation from the CDC includes PPE recommendations, training, and decontamination steps specific to fentanyl.
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References and Additional Education Links |
- Which type of personal protective equipment (PPE) and which method of donning and doffing PPE carries the least risk of infection for healthcare workers? Retrieved from: https://www.nature.com/articles/s41432-020-0097-3
- Forensic Laboratory Standards for Prevention Monitoring, and Mitigation of DNA Contamination. Retrieved from: https://www.nist.gov/system/files/documents/2019/08/19/standards_for_prevention_monitoring_and_mitigation_of_dna_contamination_draft.pdf
- Guide for the Selection of Personal Protective Equipment for Emergency Responders, NIJ Guide 102-00, Volume 1, November 2002. Retrieved from: https://www.ncjrs.gov/pdffiles1/nij/191518.pdf
- Las Vegas Metropolitan Police Forensic Safety Manual. Retrieved from: https://www.lvmpd.com/en-us/Documents/ForensicLabManuals/Safety_Manual_10-04-2019_ARCHIVED.pdf
- Austin Texas Forensic Science Bureau Safety Program. Retrieved from: https://apdforensics.qualtraxcloud.com/ShowDocument.aspx?ID=2014
- Raleigh/Wake City-County Bureau of Identification Crime Laboratory Division Health and Safety Manual 2013. Retrieved from: https://forensicresources.org/wp-content/uploads/2019/12/CrimeLaboratoryHealthandSafetyManual.pdf
- Decontamination and Reuse of Filtering Facepiece Respirators. Retrieved from: https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/decontamination-reuse-respirators.html
- Summary for Healthcare Facilities: Strategies for Optimizing the Supply of N95 Respirators during the COVID-19 Response. Retrieved from: https://www.cdc.gov/coronavirus/2019-ncov/novel-coronavirus-2019-SupplyChecklist_of-N95-Respirators_COVID-19_4_6_20_num.pdf
- Strategies for Optimizing the Supply of Facemasks. Retrieved from: https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/face-masks.html
- Personal Protective Equipment. Occupational Safety and Health Administration. Retrieved from: https://www.osha.gov/personal-protective-equipment
- Hierarchy of Controls. The National Institute for Occupational Safety and Health. Retrieved from: https://www.cdc.gov/niosh/topics/hierarchy/default.html
- Hazard Prevention and Control. Occupational Safety and Health Administration. Retrieved from: https://www.osha.gov/shpguidelines/hazard-prevention.html
- Personal Protective Equipment. The National Institute for Occupational Safety and Health. Retrieved from: https://www.cdc.gov/niosh/ppe/default.html
- Evaluation of Occupational Exposures to Illicit Drugs at Forensic Sciences Laboratories. March 2020. Health Hazard Evaluation Program. Retrieved from: https://www.cdc.gov/niosh/hhe/reports/pdfs/2018-0116-3370.pdf
- Preventing Emergency Responders’ Exposures to Illicit Drugs, Including Fentanyl. The National Institute for Occupational Safety and Health. Retrieved from: https://www.cdc.gov/niosh/topics/fentanyl/risk.html
- In Glowing Colors: Seeing the Spread of Drug Particles in a Forensic Lab. April 2020. National Institute of Standard and Technology. Retrieved from: https://www.nist.gov/news-events/news/2020/04/glowing-colors-seeing-spread-drug-particles-forensic-lab
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