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.

October 23, 1995

The Honorable Phil Gramm
United States Senate
310 N. Mesa
El Paso, Texas 79901

Dear Senator Gramm:

This is in response to an information request of August 15, on behalf of your constituent, Dr. Lyndon E. Mansfield, concerning the issue of latex allergy and latex hypersensitivity. Your letter was forwarded to the Occupational Safety and Health Administration (OSHA), Directorate of Technical Support for response. Please accept our apology for the delay in this response.

The OSHA Bloodborne Pathogens Standard appeared initially in the Federal Register in December 1991. It was initiated in response to the increasing risks and hazards associated with occupational exposure to infectious agents including the HIV(AIDS) and Hepatitis B viruses. The wearing of gloves by surgeons and others performing invasive procedures has been standard infection control practice for decades. The Centers for Disease Control and Prevention (CDC), considered the authorities on infection control in the U.S., had recommended for years prior to OSHA's standard that healthcare workers wear protective gloves when exposed to blood or some of the other body substances. OSHA's standard mandates that the employer shall provide such gloves at no cost to the employee when the potential for occupational exposure exists.

The standard has also considered employees with latex allergy by assuring that the employer must provide and make readily accessible hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives to those employees allergic to the gloves normally provided.

The major cause for the increase in the number of latex allergy cases is felt to result from the intense exposure of individuals, such as spina bifida patients, undergoing extensive and frequent surgical procedures (see enclosures 1-5), rather than from the use of protective gloves. The risks to health from transmission of and exposure of medical personnel to infectious agents without the use of protective gloves and the standard's requirement that the employer supply them, must be considered in addition to concerns regarding latex allergy. In addition, screening of healthcare workers can help to determine latex sensitivity and identify workers who should be offered alternative protective equipment. We have included for Dr. Mansfield's information a list of additional references on this topic (see enclosure 6).

Thank you for forwarding Dr. Mansfield's correspondence to us. Should you or Dr. Mansfield need further assistance regarding this matter, please contact our Office of Occupational Medicine at (202) 219-5003.




Stephen Mallinger
Acting Director
Directorate of Technical Support








(For attached article - "The burgeoning problem of latex sensitivity": Weido, Anthony J., M.D. and Sim, Tommy C., M.D. Postgraduate Medicine - Latex Sensitivity, vol. 98, no. 3: September 1995, pp. 173-184, see printed copy)





(For attached article - "Latex Allergy: Recognition and Management of a Modern Problem": Barton, Elizabeth C., R.N.C., A.N.P. Nurse Practitioner, vol. 18, no. 11: November 1993, pp. 54-58, see printed copy)

(For attached article - "How Common is Latex Allergy? A Survey of Children with Myelodysplasia": Pearson, Michele L., Cole, Jeane Stilwell and Jarvis, William R. Developmental Medicine and Child Neurology, vol. 36: 1994, pp. 64-69, see printed copy)

(For attached article - "Latex Anaphylaxis During Spinal Surgery in Children with Myelomeningocele": Banta, John V., Bonanni, Craig and Prebluda, Jeffery. Developmental Medicine and Child Neurology, vol. 35: 1993, pp. 540-548, see printed copy)

(For attached article - "Saving Careers and Lives": Libowitz, Lisa. Johns Hopkins Asthma and Allergy Center Update, vol. 4, no. 1: Fall 1995, see printed copy)

(For attached report - Toxline 1990-3/95: PC-SPIRS 3.30, search produced 13 abstracts, see printed copy)