Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

April 24, 1992

Steven Schatzow Morgan,
Lewis & Bochus
Counselors at Law
1800 M Street, N.W.
Washington, D.C. 20036

Dear Mr. Schatzow:

This is in response to your letter of March 11, requesting a clarification of the Occupational Safety and Health Administration (OSHA) standard on Occupational Exposure to Bloodborne Pathogens, 29 CFR 1910.1030, and is pursuant to the March 2 meeting you had with two members of my staff.

You are correct in your statement that "at the present time...OSHA require[s] the use of a tuberculocidal disinfectant to clean up blood or body fluids". We also appreciate your concern that OSHA clarify its position that the use of quaternary ammonium compounds is appropriate for housekeeping procedures which do not involve the clean-up of contaminated (defined as the presence or reasonably anticipated presence of blood or other potentially infectious materials) surfaces. Such a clarifying statement will be inserted into a subsequent change of OSHA Instruction 2-2.44C, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard". In the meantime, a copy of this letter will be forwarded to all Regional OSHA Offices.

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