Transcripts and notes follows:
Hello, my name is David King,
and welcome to my humble barber shop.
Sometimes, government regulation
can be a wonderful thing. But I’m here to warn y’all that Texas state regulators
have turned most haircutting shops into efficient distribution centers
for diseases that you should avoid.
There are any number of specific problems I could talk about, from dirty combs to dirty jars of stuff, but I’m going to highlight just three items in this video. I’ll put more information, and my address, on my website, www.kingbarber.com.
========
Here we go, and may God forgive me!
-------------------
Did you know that the Texas
laws have been changed so that we barbers no longer have to wash our hands
before we cut your hair?
The requirement used to
be two barber chairs per sink, and everybody wash their hands with soap
and water.
Then it was changed to three
barber chairs per sink, and everybody wash their hands with soap and water.
[NOTE 001]
Then in 2005, it was changed
to
three barber chairs per
sink,
OR
you could set up three barber
chairs, ignore the sinks, and just get one bottle of hand sanitizer, and
have your three barbers share. [NOTE 002]
Why they thought this was
a good idea, I don’t know.
Everybody including the
FDA (Food and Drug Administration) and the CDC (Centers for Disease Control)
agree that washing with soap and water is best, and hand sanitizer is what
you use when you don’t have soap and water available. [NOTE
003]
Even the people who make
this stuff agree.
One company says:
http://www.purell.com/page.jhtml?id=/purell/include/facts.inc
What is the proper way to
practice hand hygiene?
Use soap and water, especially
when hands are visibly dirty. Wash hands with soap and water for 15 to
20 seconds.
When soap and water are
not available, use an alcohol-based hand sanitizer. Apply enough product
to thoroughly wet hands, then rub hands together briskly until dry.
Is there a hand sanitizer better than soap and water for use in a barber shop? No. There isn’t any. Let me know if you disagree.
If you see a shop using CLARCON
hand sanitizer, Run Away. [NOTE 004]
It is contaminated with
bacteria, and the FDA has recalled that stuff, and federal marshalls have
been seizing it.
(Show on screen)
http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm164845.htm
Risk of bacterial contamination
has led the Food and Drug Administration (FDA) to warn consumers to not
use any products made by Clarcon Biological Chemistry Laboratory Inc.
The Roy, Utah, firm voluntarily
recalled some skin sanitizers and skin protectants sold under a variety
of brand names after a recent FDA inspection found that the products contained
high levels of disease-causing bacteria.
-----
Did you know that Texas law
allows us to shave someone who has a bad case of Hepatitis C, and then
re-use that very same razor blade on you?
Of course, we here at King
Barber know better than to do something as irresponsible as that.
But not the people who regulate barbers, in Austin, Texas.
Here is what they do not seem to understand about disinfectants and razor blades.
The FDA requires critical medical devices, which are any devices that contact blood, to be sterilized between uses. [NOTE 005] Now, we barbers are pretty good with razors, but even if we don’t nick you during a shave, the blade will abrade your skin (we’re always scraping), and it’s inevitable that we will draw some blood anyway. You won’t see it, but it’s there. And it will collect on the edge of the razor blade.
However, the FDA does not
regulate barber razors as medical devices. Instead, these razors are regulated
by the Consumer Product Safety Commission. So, if something happens with
this razor, then I can file my complaint with them. And somebody in Austin
decided that it would be ok not to sterilize these blood-contaminated razor
blades. Instead, they decided that it would be just fine to use a low-level
disinfectant [NOTE 006] on them, with the
razor blade, before we used them
on you.
Well, I brought this bizarre situation before the Texas Barber Advisory Board, and here is what they said back in January of 2009:
TDLR meeting [NOTE
007]
January 2009
(at the 3 hour and 11 minute
mark on the recorded meeting)
Item I
Madame Chair:
Discussion and possible
recommendation of rule change relating to the sanitation of razors
TDLR staff member:
Madame Chair, at the last
meeting there was a -- I’m sorry, Brad?
General Counsel:
This is Brad Bowman -- I’d
like to point out that in your materials that we’ve placed the current
rule that governs the sanitation of razors, for your consideration. There
is not a rule change drafted for you to vote on. This was placed on the
agenda at your request.
TDLR staff member:
At the last meeting you
may recall there was a gentleman who raised some concerns that the current
standards for sanitizing the razor were inconsistent or lower than what
should be in place. You may remember, Madame Chair, that when you sat on
the group that was working on the rules that we had plenty of data that
demonstrated that the composition of the EPA and the alcohol and the chlorine
bleach was significant, or sufficient, to cover the sanitation requirements
in this area . We have talked to Dr. Hezzletine at the time we created
the standards. So I think the position of staff are looking in the direction
of Margie and Beebie is that we believe that the sanitation provisions
as they exist are more than sufficient to cover the sanitation needs as
they relate to sanitizing razors.
Madame Chair:
After many long meetings
about that, I would tend to agree. That was the meeting that you and I
participated in, so I have no questions about that.
Barber Advisory Board member:
I have no question on it
either. I think our EPA takes care of it. It does point out, though, one
reason somebody needs to have a book or get on the internet to find it,
because he was using some information that was very old.
Madame Chair:
Ok. All right. Well, moving
right along, because I know that Joe and I put a lot of hours into that
. . .
------------------------------------------
(Back to me)
I can think of nobody, no
one anywhere, with a lick of common sense that would recommend that anybody
use somebody else’s razor blade. The medical support organizations for
hepatitis patients, and for people with liver problems all think that it’s
a bad idea. [NOTE 008]
But the barber regulators
in Austin seem to think it’s OK as long as we disinfect the blades with
Alcohol, bleach, or EPA
(an EPA-registered disinfectant).
Well, that’s just nuts.
And here’s why:
The regulators tell us to
use Alcohol to disinfect dirty razor blades.
But, the law [NOTE
009] here in Texas tells us we can’t do that:
TAC CHAPTER 82 RULE §82.101
(c)(2)
82.101(c) Isopropyl or Ethyl
alcohols shall be used as follows:
(1) isopropyl alcohol at
a concentration of at least 70% and ethyl alcohol at a concentration of
at least 90% are low-level disinfectants. [NOTE 010]
(2) Alcohol shall not be
used to clean and disinfect blood or body fluid.
(back to me)
Why can’t we do that? Because
it doesn’t work.
----------------------
The regulators tell us to
disinfect the blades with bleach.
But nobody who wants to
keep his customers
is going to soak a sharp
razor blade in bleach right before doing a shave, because
bleach is way too corrosive.
---------
The barber regulators suggest
we use an EPA-registered disinfectant. Well, there is no EPA-registered
disinfectant suitable for the job. Every label on every EPA-registered
disinfectant says,
(to screen)
"It is a violation of federal
law to use this product in a manner inconsistant with its labeling." I
don’t know what law that is, [NOTE 011] but
I’m gonna follow their directions.
And, most products are also labeled, "This product is not to be used as a terminal sterilant/high level disinfectant on any instrument that is introduced directly into the human body, either into or in contact with the bloodstream or normally sterile areas of the body." [NOTE 012]
(to me)
If a razor blade nicks your
skin, this is exactly what is going to happen to you.
Texas regulators have known since 1965 that the usual barber shop disinfectants don’t work against hepatitis on barber razors. [NOTE 013] I’ll put some medical references on my website so you can read up on the grisly details. But, this situation is truly appalling.
The rules absolutely must be changed to require that razor blades must be discarded after one use, and then, disposed of in a sharps container. And when the sharps container is full, it must be disposed of according to Texas State law. [NOTE 014]
It would also help if anyone who employs a barber would comply with the OSHA rules for barbershop safety, such as providing PPE for every employee, which would include employer-paid shots for hepatitis B, and disposable gloves, and sharps containers. It’s been a federal law since 1992. [NOTE 015]
Here’s a comment for barbers: Any barber who was employed to do shaves, who was not provided PPE and who contracted a bloodborne disease since 1992, could have grounds for a civil lawsuit against that employer.
There are about 13,000 barbers
licensed to do shaves in Texas, and another 130,000 licensed cosmetologists,
none of whom are licensed to do razor shaves, but some of them do razor
shaves anyway. From the thousands of barbers and cosmetologists who do
shaves with blood-contaminated razor blades every year, probably several
hundred people get hepatitis. And the victims are unlikely to know where
they got it from, since it takes several weeks or months before hepatitis
symptoms appear.
---------------------------
And I’d like to comment on the unhappy state of neck duster brushes. They need to be disinfected after every customer. It’s not just the law, it’s a good idea. [NOTE 016]
Disinfecting a brush is not
a difficult thing to do. Here’s a quick overview of how we do it at King
Barber.
=========================================
1) We take a clean brush
out of the SANITIZED box and use it on our customer.
2) After the haircut, we
set the brush aside
3) At the end of the day,
we collect all the brushes, and clean them up as need be.
4) We soak them overnight
in bleach water. 1000 parts per million of bleach, or 6 ounces of Clorox
bleach in a 2 gallon container. And, as I mentioned, we use plastic brushes
with smooth, non-porous bristles because EPA-registered disinfectants are
not designed for anything else.
5) The next day, we rinse
them nice and clean.
6) And we set them on a
rack to dry.
7) When they are dry, we
put them back in our SANITIZED box, and they are ready for you.
=============
As I previously mentioned, every EPA-registered disinfectant says, "Use only on non-porous surfaces." Animal hair bristles are very porous. So, we have to use brushes with non-porous nylon bristles. You can get a clear understanding of the difference between porous brush bristles and non-porous brush bristles from anyone who sells paint and brushes in a hardware store.
Whenever you let someone use a dirty neck duster brush on you, consider this . . .
They have rubbed the that brush on hundreds, maybe thousands, of faces. Some of them had colds, swine flu, ringworm, fevers, who knows what. And they’re going to rub that brush on YOUR face. No, you can’t be first, but you can be . . .
"NEXT!"
------------
I raised this issue with
the barber regulators in 2008. Their response can be found on the barber
section of the TDLR (Texas Department of Licensing and Regulation) website,
[NOTE 017]
http://www.license.state.tx.us/barbers/barbers.htm
right where it says, "Justification
for Barbers Adminstrative Rule Adoption 82.72"
"The Texas Department of
Licensing and Regulation ("Department") drafted and distributed the proposed
rule to persons internal and external to the agency. The proposed amendment
was published in the Texas Register on April 18, 2008. The comment period
closed on May 19, 2008. One public comment was received in response to
the proposed rule.
The comment suggests replacing
the proposed language of "one neck duster" with "three re-usable neck dusters
made of plastic." The commenter believes that this language will better
facilitate cleaning and disinfecting of the neck dusters. Specifying that
a neck duster must be made of plastic would allow the duster to be soaked
in a disinfectant solution, and requiring three neck dusters would allow
the student to use one duster while others are drying. The Department disagrees
with the comment and believes that the current requirement of one neck
duster is a sufficient requirement for a student kit. A neck duster, even
if not made of plastic, could be sprayed with disinfectant between clients
and generally could be immersed in a disinfectant solution for the minimum
time necessary for disinfection. While it might be advisable for students
to have more than one neck duster, the Department does not believe that
the volume of customers typically seen by students would necessitate a
requirement of three neck dusters."
------
There are two major problems
with their response to my comment.
First, in the 50 years of
my getting and giving haircuts, I have never, ever, seen anyone disinfect
their neck duster brush in this way. I doubt very seriously that anyone
ever has. It would be stupid to do this, because wet brushes can take 12
hours or more to dry.
Secondly, as I have mentioned,
all EPA-registered disinfectants are designed and labeled for use on non-porous
surfaces, and may not be used on animal hair brushes. Texas regulators
should know this by now. They have been, after all, regulating Texas barbers
and hairdressers since 1929. If they haven’t figured out things by now,
when will they?
Maybe it’s now time to let
the State of Texas Department of Health Services, which is full of people
with expertise on health issues, regulate barbers and hairdressers, instead
of the TDLR, which is full of experts on regulating elevators, fight promoters,
and tow truck companies.
----------------------------------
Now, I don’t mean to make
you think that you are going to contract some horrific disease every time
you go to your local barber or hairstylist, but I do think that you should
be aware that not every establishment is sanitary, and that you cannot
count on the current regulations to protect your health and safety.
There are other safety and
sanitation issues that need to be covered, but too much for this video.
I’ll post some additional references [NOTE 018]
and other comments on my website: www.kingbarber.com
Thank you very much.
===============================================
===============================================
NOTES:
[Note
001] -- No substantial reason is given for the change that makes
it less likely that a barber would wash his hands before performing a service.
The phrase, "The amendments clarify that . . . " doesn’t really explain
why these sanitation rules were reduced for barber shops.
http://texinfo.library.unt.edu/texasregister/html/2003/jan-31/adopted/22.EXAMINING%20BOARDS.html
TITLE 22.EXAMINING BOARDS
Part 2. TEXAS STATE BOARD
OF BARBER EXAMINERS
Chapter 51. PRACTICE AND
PROCEDURE
Subchapter D. BARBER SHOPS
22 TAC §51.93
The Texas State Board of
Barber Examiners adopts amendments to §51.93. Sanitation Rules for
Barber Shops, Schools and Colleges with changes to the proposed text as
published in the November 29, 2002, issue of the Texas Register (27 TexReg
11033). As adopted, the amendment to §51.93(f) paragraphs (7) and
(8) are being removed because they are duplicate paragraphs of §51.93(f)(5)
and (6).
The amendments clarify that
barber shops shall have not less than one sink per three (rather than two)
chairs whereas barber schools/colleges shall have not less than one sink
per two chairs.
============================================================
[NOTE 002] -- The rules were "updated to accepted industry standards," but what, exactly, does this phrase mean? What actually happened was a diminished level of sanitation in Texas barber shops:
http://texinfo.library.unt.edu/texasregister/html/2005/dec-23/PROPOSED/16.ECONOMIC%20REGULATION.html
New health and safety standard
rules are added at §§82.100 to 82.114. These new rules update
and supplement existing sanitation rules to accord with accepted industry
standards. Section 82.100 contains definitions of key health and safety
terms. Section 82.101 contains standards relating to Department-approved
disinfectants. The rule describes the manner in which each type of disinfectant
may be used. Section 82.102 contains general health and safety requirements,
such as requiring a container of liquid disinfectant at each barber chair
or station and the removal of hair cuttings as soon as practicable. Section
82.103 describes health and safety standards that apply specifically to
hair cutting, styling, treatment, and shaving.
§82.103.Health and
Safety Standards--Hair Cutting, Styling, Treatment and Shaving Services.
(a) Barbers shall wash their
hands with soap and water, or use a liquid hand sanitizer, prior to performing
any services on a client.
======================================================
[NOTE 003] Many licensed barber and cosmetology shops do not have sinks for hand washing next to their haircutters. Here is what authorities think about using hand sanitizers instead of soap and water:
http://www.cbc.ca/news/story/2007/01/04/hand-sanitizer.html
The FDA recommends soap
and water for proper handwashing, and that hand sanitizers serve as an
adjunct to control the spread of bacteria.
http://handsanitizers.blogofstuff.com/hand_sanitizer/hand_sanitizers-hand_sanitizer87.html
Interestingly enough, the
Food and Drug Administration, in regards to regulations concerning proper
procedures for food services, recommends that hand sanitizers not be used
in place of soap and water but only as an adjunct.
http://biology.about.com/od/microbiology/a/handsanitizers.htm
Almanza recommends that
to properly sanitize the hands, soap and water should be used. A hand sanitizer
can not and should not take the place of proper cleansing procedures with
soap and water.
http://wcco.com/health/soap.or.sanitizer.2.862957.html
"Hand sanitizers are no
substitute for soap and water," said Deborah Durkin, who calls herself
the "Mayor of Germ City," and helps run the Minnesota Department of Health
program to encourage hand washing.
http://rx.magazine.tripod.com/ph_20000512.htm
Often used as a replacement
for the traditional method of cleaning hands -- soap and water -- hand
sanitizers are actually too good to be true.
http://news.uns.purdue.edu/UNS/html4ever/000211.Almanza.sanitizers.html
Almanza says a hand sanitizer
can't take the place of old-fashioned soap and water at home or anywhere
else.
http://www.medicinenet.com/script/main/art.asp?articlekey=90001
Hand washing is really the
best way to prevent the spread of infection
http://www.germx.com/faq_detail.aspx?id=6
The most important difference
is the availability of soap and water. Hand sanitizer is made for washing
hands when water isn’t available.
http://www.purell.com/page.jhtml?id=/purell/include/facts.inc
What is the proper way to
practice hand hygiene?
Use soap and water, especially
when hands are visibly dirty. Wash hands with soap and water for 15 to
20 seconds. When soap and water are not available, use an alcohol-based
hand sanitizer. Apply enough product to thoroughly wet hands, then rub
hands together briskly until dry.
http://lysol.com/germ-information-center/OOP_Brochure.pdf
Remember: If soap and water
are not available, use an
alcoholbased
wipe or hand gel!
========================================
[NOTE 004] -- TDLR rules technically allow this product to be used in Texas barber shops today. When an inspector visits a shop, they probably don't know that this product is hazardous. Somebody ought to inform Texas barbers and cosmetologists not to use this stuff. The TDLR could, since they publish a quarterly newsletter . . .
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm164863.htm
FDA Warns Consumers Not
to Use Skin Products Made by Clarcon Due to Bacterial Contamination Risk
http://finance.yahoo.com/news/US-Marshals-seize-sanitizer-apf-4063002290.html?x=0
WASHINGTON (AP) -- Officers
with the U.S. Marshals Service have seized all skin sanitizers and skin
protectants, including ingredients and components, at Clarcon Biological
Chemistry Laboratory's facility in Roy, Utah, the Food and Drug Administration
said.
The FDA also warned the
public Saturday not to use any Clarcon products because they contain harmful
bacteria and are promoted as antimicrobial agents that claim to treat open
wounds, damaged skin, and protect against various infectious diseases.
No cases have been reported to the FDA.
===========================================================
[NOTE
005]
http://www.epa.gov/PR_Notices/pr98-2.html
===========================================================
[NOTE
006]
Thanks to FIFRA (the Federal
Insecticide, Fungicide, and Rodenticide Act), the FDA regulates liquid
sterilizers as medical devices. The FDA also regulates antiseptics, including
alcohol-based sanitizers. And FIFRA gives jurisdiction to the EPA over
surface disinfectants, including alcohol-based disinfectants.
All EPA-registered disinfectants
must have an EPA registration number on its label. Also, no EPA-registered
disinfectants are suitable for sterilizing anything, since they are only
general-purpose disinfectants, limited in scope to what is printed on their
label. Every disinfectant commonly found in barbershops are general-purpose
(also called "Hospital-grade" disinfectants).
FDA-regulated antiseptics
and sterilants, and EPA-regulated disinfectants, are limited to the purposes
outlined on their labels.
===================================
[NOTE
007]
http://www.license.state.tx.us/Agendas/AdvisoryBrdAgendas/baragenda011209.htm
=======================================
[NOTE
008]
http://www.cdc.gov/Features/ViralHepatitis/
http://www.ymcade.org/mrsa.cfm
http://www.hcvadvocate.org/hepatitis/hepB/HBV_Personal_Care_FS.html
Because hepatitis B is found
in infected blood at high concentrations, it can be transmitted by personal
care items such as razors and equipment used by manicurists, estheticians,
barbers and cosmetologists. This can happen when even a small amount of
infected blood, so tiny it cannot be seen, stays on equipment and comes
into contact with an open cut or sore, rash or eyes, mouth or nostrils
(mucous membranes) of another person.
http://www.hcvadvocate.org/hepatitis/factsheets.asp#Easy_eng
http://www.liverfoundation.org/education/info/hepatitisc/
http://www.usfca.edu/hps/immunize/hepatitis.htm
============================================
[NOTE
009]
As mentioned before, FIFRA
gives regulatory authority for disinfectants to the EPA, and regulatory
authority for sterilants and antiseptics to the FDA. Neither the State
of Texas nor the TDLR has the authority to unilaterally declare alcohol
an acceptable disinfectant. Bottles of 70% alcohol found in drugstores
are commonly labeled and sold for use as FDA-approved OTC (over the counter)
antiseptics, and TDLR Rules should not require Texas barbers to use these
antiseptics as disinfectants, since they are not EPA-registered, and Texas
barbers would be in violation of federal law.
If the TDLR wants to require
Texas barbers to disinfect a particular surface with an EPA-registered
alcohol-based disinfectant, they could certainly do so.
The Veridien company, as
an example, could supply both EPA-registered alcohol-based surface disinfectants:
http://www.veridien.com/viraguard/presoak.htm
as well as FDA-approved
alcohol-based antiseptics: http://www.veridien.com/viraguard/spray.htm
=================================================
[NOTE
010]
A minor point -
the Milady's Standard Textbook
of Professional Barber-Styling, Revised edition, c 1999, page 48,
and the 2nd edition of "Principles
and Methods of Sterilization in Health Sciences," by John Perkins,
and page 9 of the PSI Licensing
Test http://candidate.psiexams.com/bulletin/display_bulletin.jsp?ro=yes&actionname=83&bulletinid=178&bulletinurl=.pdf
all refer to 70% ethyl alcohol
and 99% isopropyl alcohol,
instead of 70% isopropyl
and 90% ethyl alcohol.
Someone should fix the incorrect
reference in the TDLR rules, particularly since the values in the Rules
and the licensing test disagree.
==================================================
[NOTE
011]
I found out what law it
is:
http://agriculture.senate.gov/Legislation/Compilations/Fifra/FIFRA.pdf
FEDERAL INSECTICIDE, FUNGICIDE,
AND
RODENTICIDE ACT
[As Amended Through P.L.
110–246, Effective May 22, 2008]
SEC. 12. [7 U.S.C. 136j]
UNLAWFUL ACTS.
(a) IN GENERAL.—
(2) It shall be unlawful
for any person—
(G) to use any registered
pesticide in a manner inconsistent
with its labeling;
====================================================
[NOTE
012]
This warning is not required
as long as the package label does not assert that it is ok to use as a
pre-cleaning solution for critical or semi-critical medical devices prior
to sterilization. Of course, the assumption can be made that if a particular
disinfectant should not be used to pre-clean a medical device that might
cut into human tissue, then it probably should not be used to clean a medical
device or a razor blade that might cut into human tissue.
============================================================
[NOTE
013]
http://www.swedish.org/15349.cfm
In 1965, a medical researcher
managed to trace several hepatitis B patients back to a barber who unintentionally
transmitted the disease by shaving all the patients with the same razor.
The barber had used a disinfectant, but it wasn't strong enough to kill
all the germs.
http://www.annals.org/cgi/content/full/126/5/410-b
The antiseptic fluids used
to clean the razor did not destroy the viral RNA. We wonder whether the
routine male haircut may be a risk factor for HCV infection.
http://www.hivandhepatitis.com/2006icr/icaac/docs/092906_hbv_a.html
Reuse of razor blades that
carry HBV can infect other people, the researchers concluded. "Hence, any
HBV control and prevention program should educate barbers about the importance
of contagious diseases, proper sterilization techniques, and avoiding reuse
and sharing of contaminated equipment and supplies like razor blade," they
wrote.
A medical researcher found
that hepatitis C could be transmitted via the straight razors commonly
used in barber shops to trim sideburns and necks. The researcher dunked
razors from five different barber shops into five commonly-used sterilizing
solutions. Results? None of the five solutions destroyed hepatitis C, even
though some were soaked for six hours, 24 hours, and seven days.
===============================================
[NOTE
014]
Texas tattoo artists are
required to properly dispose of used razors thusly:
http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=T&app=9&p_dir=P&p_rloc=118487&p_tloc=&p_ploc=1&pg=3&
p_tac=&ti=25&pt=1&ch=229&rl=407
(h) If shaving is required,
razors shall be single-use. The razor or razor's head must be placed in
a biohazard container after
use.
Here is one of several other
ways to get rid of used razor blades, also referred to as "blood-contaminated
sharps."
https://www.sharpsinc.com/
Another way to properly dispose
of the used razors is outlined in
http://www.tceq.state.tx.us/assets/public/legal/rules/rules/pdflib/330y.pdf
And some more ideas are here,
under "Bloodborne Pathogen Control"
http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=25&pt=1&ch=96&rl=Y
=========================================
[NOTE
015]
Here's the law -- it applies
specifically to employees hired to do razor shaving since 1992.
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=29:6.1.1.1.1.1.1.26&idno=29
Title 29: Labor
PART 1910OCCUPATIONAL SAFETY
AND HEALTH STANDARDS (CONTINUED)
Subpart ZToxic and Hazardous
Substances
Browse Previous | Browse
Next
§ 1910.1030 Bloodborne
pathogens.
(a) Scope and Application.
This section applies to all occupational exposure to blood or other potentially
infectious materials as defined by paragraph (b) of this section.
. . . . MORE AT THE OSHA
WEBSITE . . . .
and it definitely applies
to barbers, according to OSHA:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22299
". . . any employee who
has occupational exposure to blood or OPIM is included in the scope of
the standard."
==========================================
[NOTE
016]
Before 2005, barbers were
explicitly required to disinfect neck duster brushes:
http://texinfo.library.unt.edu/texasregister/html/2003/jan-31/adopted/22.EXAMINING%20BOARDS.html
(1) No barber or other person
affected by these rules shall use on any person a comb, hairbrush, hair
duster, mug, shaving brush, razor, shears, scissors, clippers, or tweezers
or any similar articles that are not thoroughly cleaned and disinfected
since last used.
The rules no longer explicitly
require that such barber items be disinfected. Oddly enough, shaving brushes
are no longer mentioned. One of the reasons for regulating the barber profession
in the first place was to deal with the problem of "Barber's Itch," which
was a fungus infection of the face, similar to ringworm, which was spread
through the use of common shaving brushes.
http://www.mayoclinic.com/health/folliculitis/DS00512
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[NOTE
017]
If you can't get to that
page, I copied the page to my website at
http://www.kingbarber.com/tdlr.htm
========================================================
[NOTE
018]
Some of the TDLR sanitation
Rules are contradictory; some TDLR rules call for barbers to use disinfectants
according to the whim of the TDLR, instead of according to the label directions.
Such as --
Rule 82.101(a)(4) says,
"In all cases the disinfectant shall be used in accordance with the manufacturers’
recommendation or other guidance in this rule."
But another rule, Rule 82.101(b)(4)
says, "Chlorine bleach may affect the long-term use of scissors and other
sharp objects so the Department does not recommend leaving items in bleach
solution beyond 2 minutes for effective disinfection (5 minutes if disinfecting
for blood contamination)."
The TDLR may have its own
opinions on the effective use of EPA-registered disinfectants, but Federal
FIFRA legislation restricts the ability for the Department to reduce the
exposure time of a disinfectant required by its manufacturer.
The TDLR declares Isopropyl
and Ethyl alcohols to be suitable disinfectants in Rule 82.101(c), again,
contrary to the Federal FIFRA law, which reserves that role for the EPA.
The TDLR is limited to requiring barbers to use EPA-registered
disinfectants according to the manufacturer's instructions as printed on
the package label.
In Rule 82.101(c)(5) and
(6), the TDLR inexplicably calls for disinfecting porous materials with
alcohol, and prescribes a recommended time. Again, The
TDLR is limited to requiring barbers to use EPA-registered disinfectants
according to the manufacturer's instructions as printed on the package
label. And since there are no EPA-registered disinfectants designed
to disinfect porous materials (such as buffer blocks and nail files), this
rule encourages improper use of disinfectants, which will inevitably lead
to spreading disease.
Rule 82.103(c) calls for
an alcohol or chlorine bleach solution to be sprayed on barber implements.
Again, The TDLR is limited to requiring barbers to
use EPA-registered disinfectants according to the manufacturer's instructions
as printed on the package label. It
is important to keep this restriction in mind, as not all bleach products
have an equal amount of active ingredient, and not all bleach products
are EPA-registered.
Rule 82.106(f) calls for
porous manicure tools to be sprayed with a disinfectant. Again, The
TDLR is limited to requiring barbers to use EPA-registered disinfectants
according to the manufacturer's instructions as printed on the package
label. And since
there are no EPA-registered disinfectants designed for use with porous
material, all the items mentioned in this section needs to be discarded
after each use.
Rule 82.110(d) declares,
"Needles shall be sprayed with a disinfectant before use." Again, The
TDLR is limited to requiring barbers to use EPA-registered disinfectants
according to the manufacturer's instructions as printed on the package
label.
Any barber shop or barber school that provides manicure/pedicure services and is required to sterilize items in a sterilizer should also be required to periodically test the sterilizer for proper operation. As an example, The State of Texas, Department of State Health Services, requires tattoo artists to both use and periodically test sterilizers.
Here's the Rule covering
their obligations to ensure public health and safety:
http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_
tac=&ti=25&pt=1&ch=229&rl=407