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.

April 4, 1992

Susan K. Moore, D.P.M.
1000 Grand Canyon Parkway
Suite LL-1
Hoffman Estates, Illinois 60194

Dear Dr. Moore:

This is in response to your letter of March 2, in which you requested clarification concerning the requirements of 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens."

This regulation states that the body substances to which universal precautions must be applied are blood and other potentially infectious materials. Toenail clippings and skin shavings are included if they are contaminated with blood or blood components, such as exudates from wounds.

Similarly, nail clippers and tissue clippers which are contaminated with blood or other potentially infectious materials would be considered sharps which must meet the handling and labeling requirements of the standard if they are capable of penetrating the skin. "Contaminated" means the presence or reasonably anticipated presence of blood or other potentially infectious material on an item or surface.

The Occupational Safety and Health Administration (OSHA) expects that these instruments would be disinfected regardless of their coverage under this regulation due to the possibility of transmission of non-bloodborne diseases.

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


Dorothy L. Strunk
Acting Assistant Secretary

March 2, 1992

Ms. Dorothy L. Strunk
Acting Assistant Secretary of Labor
RM S2315
200 Constitution Ave. NW
Washington, DC 20210

Dear Ms. Strunk:

I am writing for clarification or ruling regarding the following questions:

1. Are nail clippers, tissue clippers, etc. considered as sharps?

2. Are toenail clippings and skin shavings from bottom of feet considered hazardous?

3. Orthopedic discards - casts?

I will be looking forward to hearing from you.


Susan K. Moore, D.P.M.