Hand Washing Products

OSHA 1910.1030(d)(2)(iii)
Employers shall provide hand washing facilities which are readily accessible to employees.

When provision of hand washing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleaner in conjunction with clean cloth/paper towels or antiseptic towelettes.  When antiseptic hand cleaners or towelettes are used, hands shall be washed with soap and running water as soon as feasible.

Explanation, Section 9 - IX p44/129
... requiring employers to provide ...Facilities for proper hand washing need to be readily available in all areas where occupational exposure to bloodborne pathogens is anticipated.

Recommendations for Tattooing Practices, NewYorkCity DOHMH(5)(.1)
A separate handwashing sink equipped with liquid soap, hot and cold running water and paper towels must be available in the work area.

OSHA 1910.1030(d)(2)(v)  Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment.
OSHA 1910.1030(d)(2)(vi) 
Employers shall ensure that employees wash hands and any other skin surface with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

Explanation, Section 9 - IX p44/129
...OSHA has long recognized hand washing as a major precept of infection control.
...employees must wash their hands immediately or as soon as possible after removal of gloves...
...Because gloves may not provide complete protection, basic hand washing remains a fundamental element of infection control practices.
We believe that hand washing must be stringently enforced."

Handwashing Sink by Westley Wood
(e)(3) are specific for HIV and HBV research facilities" because of  "the very high concentration of virus in these facilities."

"The requirement for a hand washing sink [paragraph (e)(4)(iii)] is to allow for hand washing prior to exiting the work area and to keep environmental contamination to a minimum by requiring that the sink be foot, elbow and automatically operated." Summary p.98

 "Hands and other skin surfaces should be washed immediately and thoroughly if contaminated with blood or OPIM..."
CDC, Recommendations. Ex. 6-153 OpCit Summary p.61

"Immediately and thoroughly wash hands and other skin surfaces that are contaminated with blood...fluids to which universal precautions apply." CDC, Update: Universal Precautions (Ex. 6-426)

Recommendations for Tattooing Practices, New York City DOHMH(5)(.1)
Hand washing is the first step in any infection control program.

Surgical hand disinfection is another matter.
"The object of surgical hand disinfection is to render the skin free
of bacteria, thus preventing the escape of organisms into the
operation wound through the punctures in surgical gloves, which
occur frequently during operations." (Sebben 1983; O'Connor 1984)
"Chlorhexidine" by GW Denton (Block, p 282)

"Both aspects of scrubbing (initial reduction and the subsequent
re-establishment of the skin's microbial flora on the hands) are
important, but the ultimate purpose of the scrub is to reduce the
level of organisms in the glove in the event that the glove is
either cut or torn."
"Methods of Testing Antiseptics," MK Bruch, (Block p 1032)
1) The longer gloves are worn the greater the amount of
moisture and growth of microorganisms. 
Piercing is minutes quick so it is unlikely microorganisms will have the same opportunity as in tattooing.

2) For tattooing it would seem obvious that

  • knurled grips requiring pressure and rubbing of the glove to hold and manipulate the tattoo machine, pose a threat to the integrity of the glove and therefore should be changed regularly.
  • stretching the skin with the other hand also stretches the glove and adds a burden to elasticity and it would be reasonable to assume holes would increase.

Fortunately, in the tattoo process the skin oozes fluid and
is constantly pushing everything up, not like an open and
exposed surgical wound wherein things could fall into the wound bed. Things can't fall into a piercing or tattoo though microorganisms can migrate into breaks in the skin.

If the outside of a glove or an ungloved hand had infectious
microorganisms, this would increase the likelihood of infection by
rubbing those infectious agents into the tattoo abrasion.

In "open exposed surgical procedures"
(this expression clearly provides a fundamental difference between surgical wounds and piercing or tattoo)
-- in contrast to tattoo --
only open exposed surgical procedures can directly introduce 
sweat, skin shedding and microorganisms directly into 
normally "sterile" areas of the body, not tattoo or piercing.
Extensive requirements for surgical procedures are for surgical procedures in hospitals or other health-care settings
and are not justifiably applicable to tattoo or piercing.


Hand washing suggestions, such as a scrub up the elbows, for an ear piercing
would seem ridiculously extreme and we believe unsupportable with even a hint of likelihood of hazard.

Patient care workplace practices are far different than a studio where pathogenic organisms are not likely to be present.

Patient care requires consideration of more particular considerations like
1. What microbial flora is on the hands.
    a) the types: resident, transient, infectious
    b) occupation dependent, where the hands travel and touch and the likelihood of which microorganisms being present. 

For example, we shake hands without fear in public.  Should we as quickly shake hands with nurses and doctors in a hospital setting.

Donning gloves is optional for personnel who perform phlebotomy.

As tattooist/piercers we have the same rights as any other group not to be burdened with requirements that are inappropriate for the circumstances especially if the rish is negligibile and not likely.  Our circumstances don't require surgical hand scrubs up to the elbows before and after procedures. Hands should be maximally free of dirt and contamination by routine hand washing procedures and soap and water is sufficient.

2. Which microbial flora should be removed or killed.
    a) to what extent, how thoroughly
    b) under what circumstances of need to be free of
    c) how much flora and how is this to be accomplished.y

There are different microbes presenting different levels of threat that depend on conditions.  We would not expect that personal hygiene emulate surgical hand scrubs, so there are levels of appropriate and differing requirements.