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.

April 15, 1996

John C. Whitener, O.D., M.P.H.
American Optometric Association
1505 Prince Street
Alexandria, Virginia 22314

Dear Mr. Whitener:

Thank you for your letter of March 15, concerning the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard, 29 CFR 1910.1030. You asked whether doctors are required to wear gloves while fitting patients with contact lenses.

The standard defines occupational exposure as reasonably anticipated contact with blood or other potentially infectious materials. In OSHA's view, the situation that you describe is routine contact lens care where there is no occupational exposure to bloodborne pathogens, and personal protective equipment is not required. However, in rare cases, such as one involving traumatic injury to the eye where occupational exposure to bloodborne pathogens is reasonably anticipated, the wearing of gloves is necessary to be in compliance with 1910.1030.

We trust the above satisfactorily addresses your concerns. Thank you for your interest in occupational safety and health.


Ruth McCully, Director
Office of Health Compliance Assistance