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 http://www.osha.gov.

April 15, 1992

Ms. Chris Mullaney
Branch Safety Officer
Laboratory of Clinical Medicine
1212 S. Euclid Ave.
Box 5017
Sioux Falls, South Dakota 57117

Dear Ms. Mullaney:

This is in response to your letter of January 20, requesting Occupational Safety and Health Administration (OSHA) guidance on the wearing of gloves when handling unopened specimen containers. We apologize for the delay in this response.

The personal protective equipment (PPE) requirements in 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens", are performance oriented. The standard requires that the type and amount of PPE be chosen to protect against contact with blood or other potentially infectious materials based upon the type of exposure and quantity of these substances which can be reasonably anticipated to be encountered during the performance of a task or procedure.

For example, gloves must be worn when it can be reasonably anticipated that the employee may have hand contact with blood or other potentially infectious materials and when handling or touching contaminated items or surfaces.

Your question concerns the handling of specimen containers which contain sera. Because sera is clear, contamination of the containers would not necessarily be visible. We therefore agree with you that gloving is appropriate when handling these containers within the laboratory, although not necessarily required by the standard. When outside contamination of the primary container is suspected or likely to occur, they must be placed in secondary containers which would prevent leakage. This would negate the need for all employees who contact them to don gloves.

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


Patricia K. Clark, Director
Directorate of Compliance Programs