760-1405 Plan Review; Construction or Pre-operational Inspection
Condensed version.

1. Floor Plan

a. When a body art establishment ..constructed...remodeled...converted...properly prepared plans and specification...must be submitted to the department...

b. All construction...shall be done in accordance with approved plans.

c. ...application

2. ...pre-operational inspection...prior to opening...

The topic of sanitation in food manufacturing operations encompasses a wide array of subjects including food plant design and construction, process equipment, cleaning and sanitizing, hygienic practices by employees, control of pests including insects and rodents, packaging sanitation, sanitation of food storage facilities, etc. p791, Sanitation in Food Manufacturing Operations, Walker, LaGrange, Disinfection, Sterilization and Preservation, SS Block

In food processing, all these subjects have a direct contamination exposure to food and are the subject of great concern.

Any program designed to reduce exposure must first examine the subject to determine the probably routes of exposure.  Unfortunately this is not done for body arts and so a quick fix of appending food operation requirements was applied.

This is not acceptable.

The premises play no role in exposure to blood borne pathogens in body art settings the same way that hospital premises are not a source of exposure.

This is recognized for hospitals and we therefore believe they apply to our setting.

As a matter of interest, the interpretation is that clients contaminate the hospital, not vice versa.

Further, it is a premise for CDC recommendations when cleaning housekeeping surfaces.

E. Keep housekeeping surfaces (e.g., floors, walls, tabletops) visibly clean on a regular basis and clean up spills promptly (279). Category II
1. Use a one-step process and an EPA-registered hospital detergent/disinfectant designed for general housekeeping purposes in patient-care areas where 1) uncertainty exists as to the nature of the soil on the surfaces (e.g., blood or body fluid contamination versus routine dust or dirt); or 2) uncertainty exists regarding the presence of multidrug resistant organisms on such surfaces (272,274,280,281). Category II
2. Detergent and water are adequate for cleaning surfaces in nonpatient-care areas (e.g., administrative offices). Category II
3. Clean and disinfect high-touch surfaces (e.g., doorknobs, bed rails, light switches, and surfaces in and around toilets in patients' rooms) on a more frequent schedule than minimal-touch housekeeping surfaces. Category II
4. Clean walls, blinds, and window curtains in patient-care areas when they are visibly dusty or soiled (270,282--284). Category II

June 6, 2003 / 52(RR10);1-42 Recommendations of CDC and the Healthcare Infection Control Practices Advisory Committee (HICPAC)

Except on rare and special instances (as mentioned below), items that do not ordinarily touch the patient or touch only intact skin are not involved in disease transmission, and generally do not necessitate disinfection between uses on different patients.

CDC Sterilization or Disinfection of Medical Devices: General Principles

Any Doctor's procedure room for colonoscopy or minor surgeries will quickly reveal a typically constructed dropped ceiling, open storage areas and a host of features that would not meet the requirements set forth for body art.  Next time you go to your health care provider take a look around. The premises are not a contributing exposure factor.

There is no evidence that the premises have any effect on infection rates and many commentators including OSHA and the CDC work on the same premise.

These are personal views and opinions of Wes Wood and do not necessarily represent the views and opinions of Unimax Supply Co Inc.
Copyright 2006