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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.
February 14, 2006
Mr. William E. Daniels
PO Box 776
Silver Creek, GA 30173-0776
Dear Mr. Daniels:
Thank you for your letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP) regarding your concerns about potential health risks from handling an object which contained dried blood. Your questions are restated below followed by OSHA'responses. This letter constitutes OSHA'interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.
Question 1: I am a mechanic and was asked to change a blood stained seat on a company vehicle. I was not told prior to beginning work on the seat that there was dried blood on it and I am now concerned since I generally have cuts/scratches on my hands from my usual work as a mechanic. Are there any diseases that a person can contract from exposure to dried blood?
Reply 1: In general, bloodborne illnesses are spread when blood from an infected person enters the body of a person who is not infected. A greater likelihood of contracting an illness from blood exposure would be expected from direct contact with liquid or semi-liquid blood or other potentially infectious materials (OPIM) or from contact with dried blood that is easily flaked off. The most common routes of exposure which present potential for concern are: a) contact with contaminated sharps (i.e., needle stick or other sharp injury), b) contact of infected blood to mucous membrane (i.e., blood/bodily fluid splashed to eyes, nose or mouth), or c) contacting dried blood released from a surface onto non-intact skin.
In your letter, you mentioned that the vehicle was soiled on a Friday and remained unused until you began working on it the following Monday, at which time, the blood was dried. You also mentioned that the seat had foam padding. Although some bloodborne pathogens (e.g., Hepatitis B) are known to remain viable on surfaces for some time, it is difficult to determine whether the foam padded seating would allow release of liquid or semi-liquid blood or the flaking off of dried blood.
The Centers for Disease Control and Prevention (CDC), has published information which provides an overall explanation of bloodborne diseases, risk factors for infection, viability timeframes outside the body and recommended treatment for infected persons. Some of these documents include Viral Hepatitis C (HCV) & Viral Hepatitis B (HBV) Fact Sheets and Frequently Asked Questions documents. You may access these and other helpful documents at http://www.cdc.gov/ncidod/diseases/hepatitis/c/index.htm.
Question 2: Are there any regulations that should have required an employer to notify an employee ahead of time if he/she is to begin working on an object containing dried blood?
Reply 2: OSHA's bloodborne pathogens standard, 29 CFR 1910.1030 requires that employers make the determination whether any employee has a potential for occupational exposure to blood or OPIM. This standard defines "occupational exposure" as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties." Generally, the task you were assigned would not be considered to have "reasonably anticipated exposure," and therefore, OSHA would not consider your employer to be required to implement all the provisions of the bloodborne pathogens standard.
Question 3: Is there anything that can be done after the fact for my protection from a disease as a result of an exposure that I may have had while working on the seat?
Reply 3: It is very difficult for us to assess the risk given the brief description in your letter. You may want to consult with a healthcare professional to determine what risks, if any, you may have had. You may want to contact your personal physician for further consultation.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.
Richard E. Fairfax, Director
Directorate of Enforcement Programs