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June 29, 1993

Ms. Jill Haukos
Associate Director for
Special Projects
Texas Tech University
Health Sciences Center
School of Medicine - Department of
Preventive Medicine
NPTN-Antimicrobial Complaint System
Lubbock, Texas 79430

Dear Ms. Haukos:

This is in response to your letter of April 5 regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Specifically, you requested confirmation of information received during a telephone conversation you had with a member of my staff.

The information you received was as follows, according to your correspondence:

1. OSHA Instruction CPL 2-2.44C is still the current version. Proposed revisions have not been approved and published yet.

2. OSHA assumes that a product labeled for TB will be effective against HIV-1 and, therefore, HIV-1 label claims are not needed for compliance with the bloodborne pathogens regulation. Questions on this topic should be routed to the Regional Bloodborne Pathogen Coordinator with the regional OSHA offices.

3. OSHA will accept an HIV-1 label claim for products being used in HIV-1 research laboratories where that is the only pathogen that could be found in the samples (blood or tissue culture, etc...). If there is any chance of HBV, the lab will need a TB effective product.

All of these statements are correct, however we would like to add to item #3. If there is any chance of not only HBV presence, but presence of any bloodborne pathogen other than HIV, the lab will need a tuberculocidal disinfectant.

We hope this information is responsive to your concerns. Thank you for your interest in employee safety and health.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs




April 5, 1993

Laura Lewis
Office of Compliance Programs
Occupational Safety
and Health Administration
Washington, D.C. 20210

Dear Ms. Lewis:

Thank you for assisting our organization in understanding OSHA's stance on antimicrobial products for compliance with the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens". In order to communicate this information to our callers, we need verification that we have interpreted it correctly. Therefore, we would appreciate your review of the information below:

1. OSHA Instruction CPL 2-2.44C is still the current version. Proposed revisions have not been approved and published yet.

2. OSHA assumes that a product labeled for TB will be effective against HIV-1 and, therefore, HIV-1 label claims are not needed for compliance with the bloodborne pathogen regulation. Questions on this topic should be routed to the Regional Bloodborne Pathogen Coordinator with the regional OSHA offices.

3. OSHA will accept an HIV-1 label claim for products being used in HIV-1 research laboratories where that is the only pathogen that could be found in the samples (blood or tissue culture, etc...). If there is any chance of HBV they will need a TB effective product.

Please indicate that you agree with these statements by signing the signature block below:

___________________________________         ______________________
Laura Lewis, Compliance Office OSHA         Date

Sincerely,



Jill F. Haukos
Associate Director
for Special Projects