OSHA
Department of Veterans Affairs
Washington, DC 20420
VA Directive 7701
Transmittal Sheet
July 8, 1998
LATEX SENSITIVITY/ALLERGY
1. REASON FOR ISSUE: This directive establishes policy for the management
of natural rubber latex sensitivity/allergy for patients and employees.
2. SUMMARY OF CONTENTS: This directive sets forth the polices and
responsibilities for managing and implementing the VA’s latex sensitivity
and allergy policy.
3. RESPONSIBLE OFFICE: Office of Occupational Safety and Health (00S1),
Assistant Secretary for Human Resources and Administration
(006)/Designated Agency Safety and Health Official (00S). If you have any
questions concerning this directive, contact the Office of Occupational
Safety and Health at (202) 273-9745.
4. RESCISSION: None.
CERTIFIED BY: BY DIRECTION OF THE SECRETARY OF VETERANS AFFAIRS:
Signed by Nada D. Harris
Nada D. Harris
Deputy Assistant Secretary for Information Resources Management
Signed by Eugene A. Brickhouse
Eugene A. Brickhouse
Assistant Secretary for Human Resources and Administration
Distribution: RPC: 5233 assigned.
FD This distribution same as RPC: 1096.
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LATEX SENSITIVITY/ALLERGY
1. PURPOSE. This directive establishes Department of Veterans Affairs (VA)
policy for the management of natural latex sensitivity/allergy for
patients, volunteers, and employees. With this policy, VA establishes
requirements more encompassing than those required by regulatory agencies
(i.e., OSHA and FDA). If a regulatory agency establishes more strict
requirements the more strict requirements take precedent.
2. POLICY/BACKGROUND
a. Policy. It is the policy of VA to prevent, wherever feasible, exposure
to natural latex by at-risk patients and employees.
b. Background
(1) Natural rubber comes from the milky sap of certain species of plants.
Natural rubber is made into natural rubber latex through a manufacturing
process. Natural rubber latex, also known as natural latex,
sensitivity/allergy may be the result of a genetic predisposition of the
immune system to negatively react to natural latex. The risk of latex
sensitivity/allergy exists when a person having a predisposition to react
to natural latex comes into contact with natural latex. The degree to
which a person having a natural latex sensitivity/allergy reacts to the
natural rubber proteins in natural latex is dependent on the sensitivity
of the patient, how the natural rubber proteins enter the body (e.g.,
inhalation of powder or direct skin contact), the rate the natural rubber
proteins enter the body, and the frequency or magnitude of exposure to the
natural latex. Responses of persons with natural latex sensitivity/allergy
vary from mild irritation to serious (e.g., respiratory distress) or life
threatening reactions (e.g., anaphylactic shock). Often a natural latex
sensitivity/allergy may be mistaken for skin irritation or allergies from
other agents. Likewise, the reverse is also true, and
sensitivities/allergies to other substances may be mistaken for a natural
latex sensitivity/allergy. In persons with mild forms of natural latex
sensitivity/allergy, there is no way to predict if the reaction will
become more severe.
(2) Health care workers have been identified by the Occupational Safety
and Health Administration (OSHA), Centers for Disease Control and
Prevention (CDC), professional associations, and unions as being at an
increased risk of developing or aggravating a predisposition to natural
latex sensitivity/allergy. The Designated Agency Safety and Health
Official’s Letter 00S-97-6, dated June 26, 1997, and the Veterans Health
Administration (VHA) letter, dated January 17, 1997, provides additional
information concerning natural latex sensitivity/allergy.
(3) The National Institute for Occupational Safety and Health (NIOSH)
recommends, in an alert dated June 1997, that employers adopt policies to
protect workers from undue natural latex exposure. This directive is in
alignment with those recommendations.
(4) This directive addresses natural latex protein sensitivity/allergy and
does not address other substances (e.g., rubber accelerators such as
thiurams, carbamates, and benzothiazoles) contained in some latex products
that may cause sensitivity/allergic reactions.
(5) Synthetic latex does not contain natural rubber.
(6) Veterans Integrated Service Network (VISN) Directors have been
provided the videos Protecting Against Latex Allergy by the Spina Bifida
Association of America and The Latex Allergy Dilemma by Envision
Incorporated, which can be used for training.
3. Responsibilities
a. Facility Directors must:
(1) Minimize employee contact and exposure with natural latex.
Specifically:
(a) Procure only gloves that are synthetic or have the lowest available
content of natural latex protein;
(b) Ensure that employees use the correct protective gloves for the
identified task, i.e., use natural latex gloves only when indicated; food
service, housekeeping, sanitation, laundry, central service, and similar
workers do not require this type of glove in order to perform their
duties; and
(c) Implement procedures to advise at risk patients (e.g., verbally) prior
to the use of natural latex gloves that such use will expose them to
natural latex.
(2) Eliminate materials recognized as vehicles for or assisting with the
absorption of natural latex, where possible. Specifically:
(a) Purchase or use of powdered natural latex gloves only when their use
is deemed medically essential; and
(b) Use skin emulsions/moisturizers that are made to be used in medical
settings and do not hasten the absorption of natural latex through the
skin.
(3) Provide reasonable accommodations for those with natural latex
sensitivity/allergy. Refer health care workers with symptoms of natural
latex sensitivity/allergy to the Employee Occupational Health Practitioner
for possible referral to an allergist. Where there is a potential
sensitivity/allergy the Employee Occupational Health Practitioner will
work with the facility industrial hygienist or safety official, human
resource specialist, and appropriate supervisors to provide reasonable
accommodations. For example, if an employee is allergic to latex, he/she
will be provided appropriate equipment to allow them to do their job.
(4) Job applicants may not be asked about the existence, nature, or
severity of a latex sensitivity/allergy, only about their ability to
perform specific job functions. The mere existence of a latex
sensitivity/allergy is not a reason for not hiring a job applicant.
b. The facility Chief of Staff
(1) Ensures that diagnostic testing of workers/volunteers with a positive
history of natural latex sensitivity/allergy (contact dermatitis,
pruritis, urticaria, eryethema, burning or tearing eyes, angioedema,
laryneal swelling, bronchospasm, hypotension, tachycardia, and
anaphylaxis) or would qualify as an at risk patient is performed as
appropriate. Routine diagnostic tests of workers/volunteers who do not
have a positive history of natural latex sensitivity/allergy or would
qualify as an at risk patient is not recommended.
(2) Ensures that the Employee Occupational Health Practitioner is notified
when a claim concerning latex sensitivity/allergy has been filed.
c. The Human Resource Specialist. The Human Resource Specialist shall
ensure that if an injury/illness occurs involving latex, Office of
Workers’ Compensation Programs (OWCP) Form CA-2, Notice of Occupational
Disease and Claim for Compensation, would be completed using the following
codes:
(1) Source Code. The source code used would be either:
(a) 0771 for natural latex; or
(b) 0772 for a chemical component of latex (e.g., thiurams);
(2) Type Code. A type code would also be selected from the currently
available codes (e.g., 710 for inhalation or 730 for absorption);
(3) Nature of Injury. The nature of injury should include a statement of
either:
(a) Sensitivity/allergy of a systemic/respiratory and/or cardiovascular
nature; or
(b) Sensitivity/allergy of a dermal/cutaneous [e.g., uricaria and
flushing] nature.
(4) Injury/Illness. If an injury/illness does not require a CA-2 to be
submitted to OWCP, the document would be filed in the employee’s medical
record.
d. Facility Safety Committee. The Facility Safety Committee shall review
facility strategies for reducing employee exposure to natural latex
whenever a worker is diagnosed with latex allergy/sensitivity.
4. REFERENCES
a. Recordkeeping and Reporting Guidelines for Federal Agencies, OSHA
publication 2014.
b. Designated Agency Safety and Health Official’s Letter 00S-97-6,
Occupational Latex Allergies, dated June 26, 1997.
c. Public Law 91-596, Occupational Safety and Health Act of 1970, dated
December 29, 1970.
d. Executive Order 12196, Occupational Safety and Health Programs for
Federal Employees, dated February 26, 1980.
e. 29 Code of Federal Regulations 1910.1200, Hazard Communication, dated
February 9, 1994.
f. Health Industry Manufacturers Association: Natural Rubber Latex Allergy
FACT SHEET.
g. NIOSH Alert (June 1997): Preventing Allergic Reactions to Natural
Rubber Latex in the Workplace.
h. Natural rubber latex skin testing reagents: Safety and diagnostic
accuracy of nonammoniated latex, ammoniated latex, and latex rubber glove
extracts J Allergy Clin Immunology November 1996, Volume 98, November 5,
Part 1.
i. Barrier Durability of Latex and Vinyl Medical Gloves in Clinical
Settings American Industrial Hygiene Association, September 1997, page 672
- 676, by A. Douglas, T.R. Simon, and M. Goddard.
j. Chief Administration Officers Letter IL 16-97-001, Latex Information,
dated January 17, 1997.
k. Designated Agency Safety and Health Official Letter 00S-98-2, Coding
Office of Workers’ Compensation Claims Forms With Revised Type and Source
Codes, dated February 20, 1998.
5. DEFINITIONS
a. An At Risk Patient. An at risk patient for natural latex
sensitivity/allergy is one who has been identified as having past
reactions or who is in a high risk clinical group (i.e., having had spina
bifida, genitourinary anomalies and neurological impairments, multiple
surgeries).
b. Diagnosis/identification. Diagnosis/identification of individuals with
natural latex sensitivity/allergy is primarily based on clinical screening
in which the individual is questioned about their history of symptoms
elicited by exposure to natural latex products (e.g., balloons, gloves)
and whether they are in a high risk group for clinical natural latex
symptoms. Clinical symptoms, such as urticaria, may be good predictors of
IgE-medicated natural latex sensitivity/allergy.
c. Diagnostic Tests. There are a variety of diagnostic tests used as aids
to the clinical history for identification of latex-allergic individuals.
Most are experimental and have not been approved for clinical use.
Currently, there are three assays that are approved by Food and Drug
Administration (FDA) for the measurement of latex specific IgE antibodies
in serum. However, FDA recommends that these assays should only be used as
a confirmatory test, rather than screening, for persons in whom natural
rubber latex sensitivity/allergy is suspected based on clinical history
and risk factors. The correlation between the concentration of latex
specific IgE antibodies in serum and the severity of symptoms is
unpredictable. Latex puncture skin testing reagent is pending FDA approval
for use in adults (18 years and older).