- Standard Number:
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.
June 21, 1993
Ms. Rhoda George
Director of Environmental Services
West Park Hospital
707 Sheridan Avenue
Cody, WY 82414
Dear Ms. George:
This is in response to your letter received May 12, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Specifically, you asked for an explanation of OSHA's requirement for the use of a tuberculocidal disinfectant to clean contaminated areas.
Your letter suggested that "physical removal of the source contamination is the best means of controlling the cross contamination." It is unclear exactly what is meant by "physical removal." However, even after rinsing or scrubbing, residual blood or other potentially infectious material (OPIM) likely remains on that surface, and the surface must therefore be decontaminated.
The use of protective coverings, such as plastic wrap, aluminum foil, or imperviously-backed absorbent paper is an acceptable alternative for protecting items and surfaces against contamination, provided that the coverings are removed and replaced as soon as feasible following overt contamination or at the end of a workshift if they may have become contaminated during the shift.
Your letter states that "there are no studies to show that any inanimate object was ever the cause of an infection or disease to be transmitted." While there is no documented evidence showing transmission of HIV from environmental surfaces, there is evidence that surface contamination is a mode of hepatitis transmission. Hepatitis transmission, especially type B hepatitis, can occur by indirect means via common environmental surfaces, such as test tubes, laboratory benches, other laboratory accessories, and any other surfaces contaminated with infectious blood, serum, secretions, or excretions which can be transferred to the skin or mucous membranes.
Dr. Steven Hadler of the Centers for Disease Control (CDC) Hepatitis Branch provided the following testimony during the rulemaking process:
"...Transmission of HBV from contaminated environmental surfaces has been shown to be a major mode of HBV spread in certain areas... The HBV can survive for at least one week in dried blood on environmental surfaces or contaminated needles and instruments."
Further, researchers have been unable to propagate HBV in culture, therefore extensive virucidal testing has not been performed. Consequently, little is known about the precise inactivation kinetics of HBV by physical or chemical agents. For this reason, OSHA requires the strength of a tuberculocidal disinfectant to ensure the health and safety of employees exposed to blood and OPIM.
You felt that "good housekeeping practices and the use of an EPA registered germicide for general cleaning" would be "just as efficient," and that tuberculocidal disinfectants should be used in "high risk areas" such as operating rooms and emergency rooms. The term "germicide" is a broad term which applies to a broad range of products with varying strengths, and the EPA does not have a category labeled simply "germicide." A disinfectant known to kill bloodborne pathogens is required for adequate cleaning. Because contaminated work surfaces present the same hazard regardless of where they are located in a facility, tuberculocidal disinfectants are required wherever there is contamination from blood or OPIM, regardless of the setting. However, quaternary ammonia products are appropriate for use in general housekeeping procedures which do not involve the clean-up of contaminated items or surfaces. Please bear in mind that the term "contaminated" is defined as the presence or reasonably anticipated presence of blood or OPIM.
Your letter also raised the concern of contact time. You are correct that a ten minute contact time with liquid chemicals is generally required to achieve high-level disinfection. You stated that in your hospital, however, you do not have that much time available, and "15 to 30 seconds is about the amount of time that any surface stays wet." Cleaning methods will vary according to many factors, including the level of disinfection required and the product being used. It is the employer's responsibility to determine appropriate disinfection methods. The employer should follow the manufacturer's instructions printed on the disinfectant's label.
As you may know, the state of Wyoming operates its own occupational safety and health program under a plan approved and monitored by the U.S. Department of Labor, pursuant to section 18 of the Occupational Safety and Health Act of 1970. State plan requirements may be more stringent than federal OSHA regulations. Should you wish to contact them, they may be reached at the following address:
Director Wyoming Occupational Health and Safety Herschler Building, 2nd Floor East 122 West 25 Street Cheyenne, WY 82002
We hope this information has been responsive to your concerns. Thank you for your interest in employee safety and health.
Ruth McCully, Director
Office of Health Compliance Assistance
PATRICIA K. CLARK
DIRECTOR OF COMPLIANCE PROGRAM
US DEPARTMENT OF LABOR
AND HEALTH ADMINISTRATION
WASHINGTON, D.C. 20210
Dear Mrs. Clark
I am writing to you at this time in order to get a better understanding of OSHA's requirement for the use of a Tuberculocidal Germicide for the purpose of cleaning Blood and Body Fluids, as this is the information that I have been receiving.
I ask for this clarification, as the Wyoming OSHA office has put quite a scare into our hospitals by stating that this is the only Germicide that they will accept for use within the hospitals. One hospital that I am aware of was given 30 days in which to come into compliance, even though they did have the product in question on hand and ready to use.
In order to be in compliance, I will be putting a Tuberculocidal Germicide into my department and will use this product until such time I get the information needed or a better understanding of this requirement.
I have been in the Housekeeping field for 21 years and have been the director for 13. All of the classes and inservices that I have attended during this time all point to the fact that it is the physical removal of the source of contamination that is the best means of controlling the cross contamination and that there are no studies to show that any inanimate object was ever the cause of an infection or disease to be transmitted.
I have read quite a lot about the laboratory testing and the amount of time at room temperatures it takes to kill any bacteria, viruses, Fungus and so on; this time is 10 minute contact time. We do not have that time in the hospital, 15 to 30 seconds is about the amount of time that any surface stays wet. So here again the physical removal of the contamination is the best way we have of controlling the spread of an infection or disease.
While I understand the need to control the germicides in order to protect everyone concerned against the HBV and Tb viruses, I also feel that good housekeeping practices and the use of an EPA registered germicide for general cleaning, and using a Tuberculocidal Germicide in high risk areas such as OR areas, ER departments, and to keep on hand for cleaning in the other areas within the hospital should be just as efficient.
If I am totally wrong in my thinking that this is what the Standard meant, please correct me and send me the information needed to show my mistake.
I am also inclosing two copies of material that I received that caused me to write this letter. One from your office and the other an article by Dr. Rutala with the Department of Infectious Diseases at the University of North Carolina.
I look forward to hearing from you,
Director of Environmental Services
April 24, 1992
Morgan, Lewis & Bochus
Counselors at Law
1800 M Street, N.W.
Washington, D.C. 20036
Dear Mr. Schatzow:
This is in response to your letter of March 11, requesting a clarification of the Occupational Safety and Health Administration (OSHA) standard on Occupational Exposure to Bloodborne Pathogens, 29 CFR 1910.1030, and is pursuant to the March 2 meeting you had with two members of my staff.
You are correct in your statement that "at the present time...OSHA require[s] the use of a tuberculocidal disinfectant to clean up blood or body fluids". We also appreciate your concern that OSHA clarify its position that the use of quaternary ammonium compounds is appropriate for housekeeping procedures which do not involve the clean-up of contaminated (defined as the presence or reasonably anticipated presence of blood or other potentially infectious materials) surfaces. Such a clarifying statement will be inserted into a subsequent change of OSHA Instruction 2-2.44C, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard". In the meantime, a copy of this letter will be forwarded to all Regional OSHA Offices.
We hope this information is responsive to your concerns. Thank you for your interest in worker safety and health.
Patricia K. Clark, Director
Directorate of Compliance Programs