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.

January 26, 1993

Mr. Stan Turbyfill
Director of Safety National Linen Service
NSI Center
1420 Peachtree Street, N.E.
Atlanta, Georgia 30309

Dear Mr. Turbyfill:

This is in response to your letter of July 7, 1992, regarding the requirements of the Occupational Safety and Health Administration (OSHA) standard, 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." I understand that some of this information has been previously communicated to you in telephone conversations with Mr. David Kendal1 of this office. You specifically requested a clarification and interpretation of paragraph 29 CFR 1910.1030(d)(4)(iv) that would permit the counting of soiled health care textiles by route sales representatives during servicing of accounts. We apologize for the delay in this written confirmation of our response.

We understand that the potential conflict you wish to avoid is with the requirement of paragraph 29 CFR 1910.1030(d)(4)(iv) that contaminated laundry be handled with a minimum of agitation and not be sorted at the location of use. You have also stated the necessity of counting items at small accounts in order to verify charges to the customer and to deliver articles in replacement.

While this provision does not prohibit you from counting the laundry near or in the vehicle or in a utility/collection area because these are not locations of use, employees performing these tasks must be provided with the full protections of the standard, including training, personal protective equipment (PPE), and hepatitis B vaccine. OSHA believes that these requirements may be adequately addressed when this sorting/counting procedure takes place in a service or utility room; however certain provisions, such as those requiring removal of PPE and handwashing, may be difficult to effectively implement when this procedure occurs at the service representative's vehicle. In order to comply with the standard, National Linen Service must assure that all provisions of the standard are adequately addressed by your procedures and that the route sales representatives follow these procedures.

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


Roger A. Clark,
Directorate of Compliance Programs

Tuesday, July 7, 1992

U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Ave. N.W.
Washington, D.C. 20210
Attention: Ms. Sandler

Dear Ms. Sandler,

National Linen Service is a commercial laundry operation which services healthcare facilities and doctor's offices. During the servicing of smaller accounts the Route Sales Representative (RSR) must count the soiled linens he is picking up in order to verify his charges to the customer and to know what articles to leave for the physician or clinic.

During this activity our RSR is

1) observing universal precautions;

2) fully outfitted in a barrier gown, surgical or puncture resistant nitrile gloves, an optional mask and eye protection if wet linen is encountered;

3) generally located outside the customer's place of business at the vehicle or in a service or utility room where soiled linen is accumulated and stored;

4) instructed to handle linen for minimal agitation during counting and bagging activity and

5) Washes prior to leaving the facility.

We are requesting a clarification and interpretation of the standard (d), (iv), (A) permitting the counting of soiled healthcare textiles since the aforementioned activities are:

1) Not being conducted in the actual location of use but generally in outside at the vehicle or in a utility/collection area.

2) The employee is trained, vaccinated and performing the above mentioned functions while observing full universal precautions.

3) The employee is performing functions essential to the servicing of the account.

Thank you for your time and consideration of this issue.


Stan Turbyfill
Director of Safety