Letters of Interpretation

OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Each letter constitutes OSHA's interpretation of the requirements discussed.

Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information.

These letters of interpretation and the standards they address may not apply to OSHA State Plans. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or additional requirements. Please see OSHA-approved State Plans for more information.

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Date Title Standard Number
OSHA requirements for providing training for first aid, CPR, and BBP for prompt treatment of injured employees at various workplaces. 1910.151, 1910.151(b), 1910.266, 1910.266(i)(7), 1910.269, 1910.269(b), 1910.1030, 1910.1030(b), 1910.1030(g)(2), 1926.50, 1926.50(c)
Annual BBP training requirement for employees who have been provided more stringent training under 32 CFR Part 627 and the CDC-NIH BMBL publication. 1910.1030, 1910.1030(g)(2)(ii)
Whether dental anesthetic carpules are considered to be "contaminated sharps" or "regulated waste". 1910.1030, 1910.1030(b), 1910.1030(d)(4)(iii)(A), 1910.1030(d)(4)(iii)(B)
Use of rapid HIV antibody testing on a source individual after an exposure incident. 1910.1030, 1910.1030(f)(3)(ii)(A)
Wearing sandals in a medical office when feet do not contact blood or OPIM. 1910.1030, 1910.1030(d)(3), 1910.1030(d)(3)(i)
Requirements for covered beverages at nurses' stations. 1910.1030, 1910.1030(d)(2)(ix), 1910.141, 1910.141(g)(2)
Employer's duty to inform auto mechanic of presence of blood in vehicle being repaired. 1910.1030, 1910.1030(b)
Employer's obligation to assure the accuracy of the sharps injury log. 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(f)(3), 1910.1030(h)(5)
Use of passing trays and single-handed scalpel blade remover in a surgical setting. 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(d)(2)
"Freehand" piercing without the use of forceps or other engineering controls violates the bloodborne pathogens standards. 1910.1030, 1910.1030(d)(2)(i)
Periodic serologic testing to monitor antibody concentrations after completion of the hepatitis B vaccine three-dose series is not recommended. 1910.1030, 1910.1030(f)(1)(i)
Safety precautions, PPE, and immunizations for workers in waste water treatment facility. 1910.1030
Acceptability of DOT labeling requirements in lieu of OSHA's labeling requirements for shipments of biohazardous materials. 1910.1030(g)(1)(i)
Applicability of the bloodborne pathogens standard to persons who self-administer injectable medications. 1910.1030(b), 1910.1030(d)(2)(i), 1910.1030(d)(2)(vii)(B), 1910.1030(d)(4)(iii)(A)
Definition of contaminated sharps; engineering controls and good work practice controls must be implemented; ECP must be reviewed annually. 1910.1030(b), 1910.1030(c)(1), 1910.1030(d)(2)(i)
Containment and disposal requirements for disposable razors used in long-term health care facilities for personal grooming. 1910.1030(c)(1)(ii)(B), 1910.1030(d)(2)(i), 1910.1030(d)(4)(iii)(A), 1910.1030(d)(4)(iii)(C), 1910.1030(g)(2)(vii)(F)
Needle removal procedures for situations where other methods of disposal are infeasible or required by a specific procedure. 1910.1030(d)(1)(ii)(B), 1910.1030(d)(2)(vii)(A), 1910.1030(d)(2)(vii)(B)
Bloodborne Pathogens Standard as it relates to contaminated laundry, sharps containers, and the Hepatitis B vaccine in fitness centers. 1910.1030, 1910.1030(a), 1910.1030(b), 1910.1030(c)(2), 1910.1030(d)(4)(iv)(A), 1910.1030(d)(4)(iv)(A)(1)
OSHA has no specific standard on autoclaving used medical instruments. 1910.1030, 1910.1030(d)(2)(viii)
Limiting factors for implementing the use of engineering controls, i.e., safety scalpels, under the Bloodborne Pathogens standard. 1910.1030(c)(1)(iv), 1910.1030(c)(1)(v), 1910.1030(c)(1)(iv)(B), 1910.1030(d)(2)(i)