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
Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles. 1910.1030, 1910.1030(c)(1)(iv)(B), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i)
Training and designation of first aid providers in general industry and construction. 1910.151(b), 1910.1030(c)(2), 1926.50(c)
Clarification from OSHA regarding the use of the NeedleguardTM in a hospital environment. 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i), 1910.1030(d)(4)(iii)
Concern of potential adverse affects from latex by consumers and health care patients with Hevea Natural Rubber Latex Allergy 1975.3, 1910.132, 1910.1030, 1910.1030(d)(3)(iii)
Bloodborne Pathogens Standard application to small healthcare facilities and the annual review of the Exposure Control Plan. 1910.1030, 1910.1030(c)(1)(ii), 1910.1030(c)(1)(iv), 1910.1030(c)(1)(iv)(A), 1910.1030(c)(1)(iv)(B)
Employer's responsibility to provide bloodborne pathogens training to lifeguards. 1910.1030, 1910.1030(g)(2), 1910.1030(h)(2)
Employer's responsibility to re-evaluate engineering controls, i.e., safer needle devices, at least annually. 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(c)(1)(iv)(A), 1910.1030(c)(1)(iv)(B)
OSHA's outreach effort to educate employers on the Needlestick safety and Prevention Act requirements. 1910.1030
Recapping of contaminated needles used in body piercing. 1910.1030, 1910.1030(d)(2)(i), 1910.1030(d)(2)(vii), 1910.1030(d)(4)(iii)(A)(1)
Electronic Mail Systems and Bloodborne Pathogens Training requirements. 1910.1030, 1910.1030(g)(2)(vii)(N), 1910.1030(g)(2)(viii)
Potential exposure to contaminated sharps in the solid waste industry. 1910.1030, 1910.1030(c)(2)(i)
Acceptable use of antiseptic-hand cleansers for bloodborne pathogen decontamination and as an appropriate handwashing practice. 1910.1030, 1910.1030(d)(2)(v), 1910.1030(d)(2)(vi)
Engineering control requirements for allergy and immunization injections. 1910.1030, 1910.1030(b), 1910.1030(d)(2)(i), 1910.1030(c)(1)(v), 1910.1030(c)(1)(iv)
Employee access to needlestick and contaminated sharps injury log requirements. 1910.1030, 1904.35(b)(2), 1904.8
Needlestick Safety and Prevention Act and the requirement to include safety-engineered sharps devices in pre-packaged surgical kits or trays. 1910.1030, 1910.1030(d)(2)(i), 1910.1030(c)(1)(v)
Evaluation of sutureless catheter securement devices to prevent needlestick hazards. 1910.1030(c), 1910.1030
Applicability of the Bloodborne Pathogens Standard to the municipal solid waste industry. 1910.1030(b), 1910.1030(f), 1910.1030(c)(2)
Plasma-derived products are considered "blood" within the meaning of the Bloodborne Pathogens Standard. 1910.1030, 1910.1030(a), 1910.1030(b)
Sharps injury logs are intended to track departments, devices, and/or procedures causing injuries, not injured employees. 1910.1030, 1910.1030(h)(5)(i)(A), 1910.1030(h)(5)(i)(C)
Safer medical devices must be selected based on employee feedback and device effectiveness, not Group Purchasing Organizations. 1910.1030(c)(1)(iv)(A), 1910.1030(c)(1)(iv)(B), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i), 1910.1030