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. This 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. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 10, 1987

Mr. William Rudrud
Product Manager
Pymah Corporation
P.O. Box 1114, 89 Rt. 206
Somerville, New Jersey 08876

Dear Mr. Rudrud:

A copy of your direct-mail advertisement for Tempa-DOT Single Use Thermometers which you sent to a school nurse in Connecticut, was forwarded to the Occupational Safety and Health Administration (OSHA), from the Connecticut Department of Health Services, for our response.

OSHA has an airborne occupational exposure standard for mercury which is a ceiling level of 0.1 milligrams of mercury per cubic meter of air. OSHA believes that exposures to mercury in high concentrations are hazardous to human health and that no workers should be exposed to such levels.

OSHA's standard for mercury (CFR 1910.1000, table Z-2), which is enclosed for your information, however, does not contain procedures for cleaning-up of mercury spills nor does it specifically address mercury in glass thermometers.

OSHA has published a general information pamphlet on mercury which briefly discusses mercury spills and a publication entitled "Occupational Heath Guidelines for Chemical Hazards" jointly published with the National Institute of Occupational Safety and Health (NIOSH) which details recommended procedures for mercury spills . Both of these publications are enclosed for you information and use. Please take note that the procedures described in both of the above OSHA publications are different from that contained in your advertisement.

The clean-up procedures detailed in your advertisement are as follows:

OSHA has definite procedures for cleaning up any mercury spill, even if it is just 1 glass thermometer:

1. A special team must be called in to clean up this spill.

2. If the spill is in a sink, the water must be shut off, the room evacuated, the trap removed and replaced with a new trap.

3. People exposed to elevated levels of mercury vapors must be tested to determine the amount of mercury that has been absorbed by their body.

These procedures appear to apply to larger scale spills and not to mercury spills from a glass thermometer. Since, to our knowledge OSHA does not have any publications or standards dealing with mercury spills from a glass thermometer, could you please notify us what OSHA publication your procedures are taken from.

A copy of this letter is being sent to Connecticut Department of Health Services.


Richard D. Edsell
Office of Science and Technology Assessment