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 9, 1992

Mr. Dean E. Thompson,
Clinical Director
Universal Health Systems, Inc.
1880 Star Batt Drive
Rochester Hills, Michigan 48309

Dear Mr. Thompson:

This is in response to your letter of January 20, regarding the acceptability of the Nebucid 880 "No Touch" Hand Disinfecting System and Dermocol Disinfectant Solution. Please accept our apologies for the delay in our response.

The Occupational Safety and Health Administration (OSHA) regulation on Occupational Exposure to Bloodborne Pathogens, 29 CFR 1910.1030, requires in sections (d)(2)(iii) and (v) that "employers shall provide handwashing facilities which are readily accessible to employees" and "ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment".

In section (d)(2)(iv), the standard permits an alternative to the standard handwashing facility: "When provision of handwashing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleaner in conjunction with clean cloth/paper towels or antiseptic towellettes. When antiseptic hand cleaners or towellettes are used, hands shall be washed with soap and running water as soon as feasible".

These requirements are based on testimony resulting from OSHA's proposed regulation and on the Centers for Disease Control's "Guidelines for Handwashing and Hospital Environmental Control". The latter states that handwashing is the preferred method of infection control and that the recommended technique involves a vigorous rubbing together of all surfaces of lathered hands for at least 10 seconds, followed by thorough rinsing under a stream of water.

The above-mentioned antiseptic alternative is allowed as an interim measure where an employer can show that soap and water are not a feasible means of handwashing, e.g. for ambulance-based paramedics, firefighters, or mobile blood collection personnel.

The Nebucid 880 may be acceptable as an alternative handwashing technique and may certainly be used following regular handwashing as a supplementary cleanser. However, where handwashing facilities are feasible, OSHA expects employers to provide them and ensure their use.

We hope this information is responsive to your concerns. Please contact us if we can be of further assistance.


Patricia K. Clark, Director
Directorate of Compliance Programs