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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 28, 1995

Paul Martin Kempen, M.D., Ph.D.
Co-Director Obstetric Anesthesia
Department of Anesthesiology
Louisiana State University Medical Center
P.O. Box 33932
Shreveport, Louisiana 71130-3932

Dear Dr. Kempen:

This is in response to your letter of April 26, addressed to Joseph A. Dear, Assistant Secretary of the Occupational Safety and Health Administration (OSHA), regarding compliance issues and intravenous (IV) drug administration.

Your letter and enclosed article describe your concerns regarding alternatives to direct hypodermic needle injection into latex ports in IV administration. These concerns appear to be based on your stated belief that OSHA and other regulatory agencies "prohibit" this practice and require needleless systems. This, however, as far as OSHA is concerned, is not the case.

The OSHA regulation, 29 CFR 1910.1030 "Occupational Exposure to Bloodborne Pathogens," does not prohibit the use of sharps or require needleless systems. OSHA does, however, require employers to establish an exposure control plan "designed to eliminate or minimize employee exposure." A significant hazard to workers is from needles and other sharp objects contaminated with blood or other potentially infectious materials. OSHA encourages employers to minimize, to the extent feasible, the handling of needles and sharps.

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


John B. Miles, Jr. Director
Directorate of Compliance Programs