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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.
June 10, 2013
Mr. Miles Free
Director, Industry Research and Technology
Precision Machined Products Association
6700 West Snowville Rd.
Brecksville, OH 44141-3212
Dear Mr. Free:
Thank you for your March 14, 2013, letter to the Occupational Safety and Health Administration (OSHA). Your letter was referred to the OSHA Directorate of Enforcement Programs for a reply. You had specific questions regarding the applicability of OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030, to the precision machining industry. You requested assistance in determining the appropriate means to respond to potential incidents in the precision turned parts industry involving blood contamination of metalworking fluids due to a worker injury. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. For clarification, your specific questions are paraphrased below, followed by OSHA's response.
Scenario: The precision turned parts industry uses powered machine tools, primarily lathes and mills, to apply precision tooling to metal workpieces to produce highly engineered components in volume. These machines may be mechanically automated by cams or may be computer mechanically controlled. Automated systems apply metalworking fluids to the metal workpieces. Sharp edges can be found on tools, workpieces, and chips. The machines are enclosed and guarded. However, there are times when a machine operator may have to change a tool, remove an accumulation of chips, or handle workpieces and thus be exposed to cutting hazards. These cuts could involve the possible loss of blood into the machine and its metalworking fluid collection system.
Question 1: What is the appropriate response to protect machine operators from bloodborne pathogens when carrying out the tasks mentioned above after metalworking fluids have been contaminated by blood?
Reply: The OSHA Bloodborne Pathogens standard only applies to "...occupational exposure to blood or other potentially infectious materials... ." 29 CFR 1910.1030(a). The standard at 29 CFR 1910.1030(b) defines occupational exposure" as "... reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials [OPIM] that may result from the performance of an employee's duties." Any job classification, duty or procedure, in which employees are reasonably anticipated to have contact with blood or OPIM is covered by the standard. 29 CFR 1910.1030(c)(2)(i).
Your description of the operation and the assigned tasks suggests there is anticipated employee exposure to sharp edges. Under those normal operating conditions, employers would be expected to implement work practices, such as having equipment operators wear appropriate protective equipment, to prevent or minimize the likelihood of lacerations and cuts. An employer who has assured those measures were taken, would avoid having machine operators with "reasonably anticipated" exposure to blood and, since there is no contact with OPIM, the standard would not apply to the machine operators in these circumstances.
However, if an employee does become injured and contaminates the metalworking fluids with blood, whether a single machine or part of a centralized fluid system, the employer would be expected to implement emergency action plan(s), to include the prompt rendering of first aid to the injured employee, mitigating causal factors to prevent further injuries, minimizing exposure of other employees to blood, and completing required injury/illness recordkeeping.
Question 2: While we believe that the petroleum-based metalworking fluids would be adverse to the survival of any infectious agents in the blood, we have been unable to locate any information in this area. How long does it take for the pathogens to be destroyed once in the metalworking fluid? Is OSHA aware of any antiseptic additives that can be added to the fluid system?
Reply: OSHA is not aware of any studies indicating that untreated metalworking fluids have any effect rendering pathogens nonviable. On the contrary, as you are probably aware, there is a substantial amount of data documenting the ability of metalworking fluids to sustain microbial growth and the adverse health effects to employees exposed to the aerosols generated from contaminated metalworking fluids. [Marchand, G., et al, Evaluation of Bacterial Contamination and Control Methods in Soluble Metal Working Fluids, JOEH, vol. 7, issue 6, 6 Jun 2010, pp. 358-366]. Adding an antimicrobial agent to metalworking fluids may minimize contamination of employees not just to potential bloodborne pathogens, but also to the potential exposure to microbial growth inherent in untreated metalworking fluids. For further information, please refer to OSHA's Safety and Health Topics webpage on Metalworking Fluids http://www.osha.gov/SLTC/metalworkingfluids).
There are a number of professional associations that may have relevant information. The Mary Kay O'Connor Process Safety Center at Texas A&M University is one such organization. Also, the National Institute for Occupational Safety and Health (NIOSH) has a safety and health topics webpage on metalworking fluids (http://www.cdc.gov/niosh/topics/metalworking). The 1998 NIOSH publication, Criteria for a Recommended Standard-Occupational Exposure to Metalworking Fluids (NIOSH Pub. 98-102), addresses additives to metalworking fluids, both water- and oil-based, to reduce the presence of microbial growth.
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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.
Thomas Galassi, Director
Directorate of Enforcement Programs