I am working for a dialysis unit that does not wear the impervious gowns during tx initiantion or discontinuation and this is there policy. I have 20 yrs of dialysis and this has never been acceptable anywhere else. Is this correct? I have read the new federal registry and it is interpreted by our Clinical Director that gowns or aprons are not necessary. What do you think?

The gowns are part of YOUR personal protection, same as your googles/shield. Your clinic can't prevent you from wearing your own fluid impervious gown. However, they don't have to supply you with them.

I think OSHA, CDC, and CMS would be concerned by any employer not providing the required protection.

I'm in a clinic which recently did away with disposable gowns for our PPE and now require us to wear cotton lab coats to our knees. They are not impervious to blood or fluid either. The disposable gowns we do have for isolation or emergency use(if our land's end lab coat gets splattered) only ties at the neck and does not have the ability to secure in the front. I have an issue with this as I dont believe either is protective of not only my pts but my staff. I've voiced my concern but admin tells me the other clinic has no problem wearing them so pretty much suck it up. I cant find anything in CDC guidelines that specify guidlelines other than check individual company policy. Any suggestions?

Check the new Conditions for Coverage at http://www.nraa.org/Documents/SC-09-01_ESRDIGs1%201_memo.pdf
§ 494.30 Condition: Infection control.
V_tag: V110 and V111

It doesn't say the facility has to supply gowns and gloves, but it does say they must:
"The dialysis facility must provide and monitor a sanitary environment to minimize the transmission of infectious agents within and between the unit and any adjacent hospital or other public areas."

I'm pretty sure this violates OSHA standards on safe work practices. If it were me I'd raise a major stink about this one. The cost of disposable gowns is insignificant compared to the risk to your staff. I thought it was an OSHA requirement that companies provide the correct PPE as well as annual training on safe practices. I think it's inexcusable for a company to put profits ahead of the safety of its employees. I'm also pretty sure that an employee can sue an employer for failure to provide a safe work environment, and this fits the bill in my opinion.

Wear the PPE

Would if I could as they stopped ordering any disposables except to keep some on hand for iso patients if needed. They supplied one cotton lab coat with the company logo and we had to purchase any additional ones. Per diem staff have to buy and are not even supplied the one. I dont feel quite comfortable using a cotton one which I know is permeable to fluids and blood. One of my staff had a large blood spill from a pt the other day and all she could do was wash it out with peroxide and since they only supply the one coat for use to use daily unless we buy them she didnt have a replacement. It did show on the other side of the lab coat, therefore it is blood exposure in my eyes. The new guidelines leave too much room for companies to put thier staff at risk.

Call your state surveyor and see how they interprete the guidelines.

Taken from CMS draft interpretive guidlines:

Staff members should wear gowns, face shields, eye wear, or masks to protect
themselves and prevent soiling of clothing when performing procedures during
which spurting or spattering of blood might occur (e.g., during initiation and
termination of dialysis, cleaning of dialyzers, and centrifugation of blood). Such
protective clothing or gear should be changed if it becomes soiled with blood...

To me that would meen, if there is a possibility of getting blood/fluids on yourself, appropriate protection must be worn.

The question is not whether to use PPE or not. The question is related to cotton labcoats replacing our standard disposable aprons or gowns where were not pervious to blood or fluids. The cotton labcoats ARE NOT impervious to fluids. Maybe I wasnt clear on my initial post. It is a money saving measure for the company as they no longer have to purchase disposable gowns, yet our labcoats are purchased from them and I dont think they are protective. Is there anything to address this in new guidelines?

OK, Lacie, Here it is and the link you can take to your boss. A cotton lab coat is not acceptable, it must be an impervious barrier to fluids. Don't risk your health and your patients health!

from the Conditions of Coverage Interpretive Guidelines (page 11 of 299)
V115

http://www.nraa.org/Documents/SC-09-01_ESRDIGs1%201_memo.pdf

Street clothes, scrub suits, or uniforms are sufficient attire within the dialysis unit, except for times when the spurting or spattering of blood, body fluids, potentially-contaminated substances, or chemicals might occur. At those times a cover garment which provides an impervious barrier to fluids must be worn. This could be a lab coat, a gown, or an apron which incorporates sleeves. The garment may open to the back or front, but must be closed in front during use for patient care. The protective garment should fully cover the arms and torso from the neck area to the thigh/knee area. Aprons without sleeves are not sufficient PPE for procedures which may result in spurting or spattering of blood.

Physicians, advanced practice registered nurses, physician assistants, social workers and dietitians must wear a cover garment which provides an impervious barrier to fluids if they are providing service to any patient in the treatment area during a time of high risk for spurting or spattering of blood, as, for example, during initiation or termination of dialysis. The garment should be changed if it becomes soiled. Visitors must be provided impervious cover garments if they are in the treatment area during initiation or termination of dialysis.

First of all, if that was me - I would be calling the local OSHA office and let them know.
Then, I would be making a copy of the CMS new condition of coverage and give it to your supervisor to "re-read", because this is spelled out very clearly.