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.

February 28, 1997



SUBJECT: EPA-Registered disinfectants for HIV/HBV


The National Office sent a memorandum dated November 1, 1996, on the same subject matter as stated above. It concerned recent inquiries from companies who manufacture and/or supply a disinfectant product(s) approved by the EPA as a disinfectant for Human Immunodeficiency Virus (HIV) and Hepatitis B virus (HBV). These companies had asked whether EPA-registered products with the new EPA label would be an "appropriate disinfectant" under OSHA's Bloodborne Pathogens standard. The earlier memo stated the product could be used under limited conditions, where HIV and HBV were the only pathogens of concern.

Following receipt of materials offering further support for use of these products, OSHA has reconsidered the limitations in the memorandum of November 1, 1996, and has decided that the policy that requires the use of EPA-registered tuberculocidal disinfectants and/or a diluted bleach solution to decontaminate contaminated work surfaces will be expanded to include EPA-registered disinfectants that are labeled as effective against HIV and HBV, provided such surfaces have not become contaminated with agent(s) or volumes of or concentrations of agent(s) for which higher level disinfection is recommended.

As is true with all disinfectant products, the effectiveness is governed by strict adherence to the instructions on the label. For example, the EPA-approved label on one of these products has a section titled "SPECIAL INSTRUCTIONS FOR CLEANING AND DECONTAMINATION AGAINST HIV-1 AND HBV OF SURFACES/OBJECTS SOILED WITH BLOOD/BODY FLUIDS." These instructions required:



  1. personal protection devices for the worker performing the task,
  2. that all blood must be cleaned thoroughly before applying the disinfectant,
  3. that the disposal of the infectious waste be in accordance with federal, state, or local regulations, and
  4. that the surface is left wet with the disinfectant for 30 seconds for HIV-1 and 10 minutes for HBV.

If you have further questions, please contact [the Office of Health Enforcement at 202 693-2190].

[Corrected 2/10/2005]