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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 29, 1992

Mr. Arthur Ashley President
Ferndale Electric Company, Inc.
1571 Mapledale
Ferndale, Michigan 48220

Dear Mr. Ashley:

This is in response to your letter to the Occupational Safety and Health Administration (OSHA) concerning coverage of construction employees under 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens". Thank you for the opportunity to clarify this important issue.

In response to numerous inquiries, we will be changing OSHA Instruction CPL 2-2.44C, "Enforcement Procedures for the Occupational Exposures to Bloodborne Pathogens Standard", to state that the recently promulgated standard on bloodborne pathogens (29 CFR 1910.1030) does not apply to construction work as defined in 29 CFR 1910.12. Please be advised that maintenance operations with actual or potential exposure to blood or other potentially infectious material are general industry activities, not construction work and, consequently, are covered by all the provisions of 29 CFR 1910.1030.


Patricia K. Clark, Director
Directorate of Compliance Programs