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 28, 1992

Ms. Rosann C. Halick, Manager,
Human Resources
East Side Clinical Laboratory
154 Waterman Street
Providence, RI 02906

Dear Ms. Halick:

This is in response to your inquiry of March 19, in which you requested a clarification on the Occupational Safety and Health Administration (OSHA) regulation, 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens". You wrote concerning the definition of "work area" as used in the standard. We apologize for the delay in this response.

Although the term "work area" is not defined in the standard, it is clear from the usage of the term in the regulation and its preface, that a work area is a part of a facility where contamination may occur as the result of work being performed. "Contamination" is defined as the presence or reasonably anticipated presence of blood or other potentially infectious material (OPIM) on an item or surface.

Section 29 CFR 1910.1030(d)(2)(xiii) of the standard requires that "specimens of blood or other potentially infectious materials shall be placed in a container which prevents leakage during collection, handling, processing, storage, transport or shipping." Accordingly, the paths between actual specimen collection and processing areas would not, themselves, be considered as "work areas." If a specimen spills during transport, the person who cleans up must be provided with appropriate tools and protective equipment and must have been trained in proper cleanup procedures.

With regard to the removal of personal protective equipment after an employee leaves a work area, OSHA Instruction [CPL 02-02-069 (formerly CPL 2-2.69)] makes the following statement on [in Section XIII D.17]: "...it is not the intent of the standard to require employees to change PPE when travelling, for example, from one hospital area to another..." However, the employer must assure that workers have been trained to avoid contaminating surfaces outside a work area. For example, a worker wearing contaminated gloves must remove them before using a telephone in an uncontaminated area.

Section 1910.1030(c)(1) requires employers to establish a written Exposure Control Plan designed to eliminate or minimize employee exposure to blood and OPIM. The situations that you describe should be included in your plan in ways that realistically recognize the potential for exposure while, at the same time, permitting employees to accomplish their assigned tasks effectively and safely. The general statements in the above paragraphs should help you in developing the required plan.

If you have further questions on this subject, please feel free to call upon [the Regional Bloodborne Pathogens Coordinator in the South Boston Regional Office at (617) 565-6923].


Patricia K. Clark, Director
[Directorate Of Enforcement Programs]

[Corrections 6/2/2005]