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 27, 1993

Herbert Haupt, M.D.
American Orthopaedic Society
for Sports Medicine
c/o Missouri Baptist Hospital
Diagnostic Center
3009 North Ballas Road, Suite 105
St. Louis, MO 63131

Dear Dr. Haupt:

This is in response to your letter of December 30, 1992, in which you made proposals regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Specifically, your proposals pertained to the sporting arena, both at the amateur and professional level. We regret the delay in providing this response.

The bloodborne pathogen standard provides protections to employees with occupational exposure. The term "occupational exposure" is defined under the standard as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties. It is the employer's responsibility to determine which, if any, employees have occupational exposure.

We agree with you that "trainers and team physicians will always be considered to have reasonably anticipated contact with body fluids." However, we note that you have made proposals for modifying the manner in which wounds are currently handled in the sporting arena in order to avoid occupational exposure to other employees, including players. These proposals include requiring that every player who is noted to have a wound of any sort be immediately removed from the game by appropriately protected trainers and team physicians, and that the player not be allowed to return to the game until an occlusive dressing has been applied to the abrasion or wound. This athlete would also continue to wear this dressing in the training room and in the shower following the event. You also recommended that mouth protectors be used to decrease the opportunity for lacerations to players' mouths and to avoid biting injuries, and that players be responsible for keeping their mouth protectors in a safe location away from other players.

Your suggestions appear to be well-reasoned and effective. We would encourage you to implement any and all of the above procedures that you feel are appropriate.

Because there is no employer-employee relationship at the amateur level of sports, OSHA has no jurisdiction over the manner in which player safety and health is achieved. However, your suggestions could certainly be implemented as matter of sound public health policy.

We hope this information has addressed your concerns. Thank you for your interest in employee safety and health.


Roger A. Clark, Director
Directorate of Compliance Programs