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.

May 12, 1992

Clarke L. Johnson, D.D.S.
Course Director
Department of Oral Anatomy
University of Illinois
272 South Kennedy Drive
Bradley, Illinois 60915

Dear Dr. Johnson:

This is in further response to your December 3, 1991, letter addressed to Senator Paul Simon which was referred to the Occupational Safety and Health Administration (OSHA) for response. You inquired about OSHA's requirements for the collection and handling of extracted teeth for use by dental students.

OSHA views natural teeth which may be used by dental students as specimens under 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens", which must be handled with universal precautions and which are subject to the containerization and labeling requirements of the standard unless they are appropriately decontaminated.

They must be placed in a container which prevents leakage during collection, handling, processing, storage, transport or shipment. The container must be labeled with the biohazard symbol along with the word "Biohazard" in the required contrasting colors or color-coded and closed prior to being stored, transported, or shipped.

When a facility uses universal precautions in the handling of all specimens, the labeling/color-coding is not required provided that the containers are recognizable as containing specimens, that all employees who will have contact with the specimens are trained to handle all specimens with universal precautions, and that the containers remain within the facility. If the specimens leave the facility during transport, shipment, or disposal, a label or color-coding would be required.

OSHA has requested the assistance of the National Institute for Occupational Safety and Health and The Centers for Disease Control in determining the proper means of decontaminating teeth so that they may be used for study without having to resort to these containerization and labeling requirements. When we receive their response, we will be pleased to forward the information to you.

Please bear in mind that while these requirements are sound health policy for any facility, in accordance with the Occupational Safety and Health Act of 1970, OSHA jurisdiction extends only to employees and health and safety in the workplace and does not cover students if they are not considered to be employees.

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


Patricia Clark, Director
Directorate of Compliance Programs

cc: The Honorable Paul Simon