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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 5, 1993

Lesa Stone, R.N., C.N.O.R.
Director Operating Room Services
University Medical Center
602 Indiana Avenue
Post Office Box 5980
Lubbock, Texas 79417-5980

Dear Ms. Stone:

This is in further response to your letter of October 12, addressed to the Occupational Safety and Health Administration (OSHA) Area Office in Lubbock, Texas. You requested an interpretation of 29 CFR 1910.1030, the "Occupational Exposure to Bloodborne Pathogens" standard. Your letter was referred to this office and we apologize for the delay in this response.

You referred to information provided to you during the national conference of American Operating Room Nurses. You wrote that one speaker stated that the OSHA standard prohibits "any hand-to-hand passing of any instrument that has a sharp point or edge." This statement is not correct mainly because OSHA does not regulate the management of uncontaminated instruments or sharps. Since they are sterile, they do not present a bloodborne pathogens transmission hazard. For this reason, the protocol of allowing the scrub nurse to pass the surgeon sterile instruments using the traditional hand-to-hand process is not precluded by the standard.

The standard does address the cleaning and reprocessing of contaminated reusable sharps in paragraph (d)(4)(ii)(E) which prohibits their storage or processing in a manner that requires employees to reach by hand into the containers where these sharps have been placed. The intent here is to avoid situations in which employees cannot see and safely handle contaminated sharps, thereby exposing them to the risk of percutaneous injury.

The standard also requires the adoption of engineering controls and work practices in order to minimize employees' exposure to blood or other potentially infectious materials. The "sharps zone" which you suggest in your letter is a work practice which may be used during the "pass back" when the surgeon is returning a now contaminated sharp instrument such as a scalpel or suture needle. This "sharps zone" could involve placing the contaminated instrument on a tray in order to eliminate the hand- to-hand passing which may result in needlesticks to the nurse with a contaminated instrument. This work practice should be addressed in the employer's exposure control plan and the entire surgical team must be familiarized with it through training in order to avoid injuries (e.g., a verbal cue could be used so that the scrub nurse is not retrieving a contaminated instrument at the same time as the surgeon is attempting to deposit an additional one).

We hope this information is responsive to your concerns and we would appreciate your sharing this information with the speaker in question. Thank you for your interest in worker safety and health.


Roger A. Clark,
Directorate of Compliance Programs