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.

September 1, 1992

Ms. Jalene Kindred
Boise Valley Asthma and Allergy Clinic
901 N. Curtis Road
Suite 100
Boise ID 83706

Dear Ms. Kindred:

This is in response to your letter in which you requested clarification concerning the use of gloves in administering routine injections under the Occupational Safety and Health Administration (OSHA) regulation, 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens."

The personal protective equipment requirements of the standard are performance oriented. That is, it is the employer's responsibility to evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective equipment in accordance with paragraph (d)(3)(i) of the standard.

At a minimum, gloves must be used where there is reasonable anticipation of employee hand contact with blood, other potentially infectious material, mucous membranes, or non-intact skin; when performing vascular access procedures; or when handling or touching contaminated surfaces or items.

In general, OSHA agrees with you that gloves are not necessary when giving routine injections as long as hand contact with blood or other potentially infectious material is not anticipated. If bleeding is anticipated and the employee is required to clean the site following injection, then gloves must be worn. Additionally, if the patient's skin is abraded, gloves would be required.


Patricia Clark, Director
Directorate of Compliance Programs