|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.|
March 19, 1999
Dr. Axel Wannag
Direktoratet for Arbeidstilsynet
Fridtjof Nansens vei 14
P.b. 8103 Dep, N-0032
Dear Dr. Wannag:
This letter is in response to your correspondence dated January 21, 1999, addressed to the Occupational Safety and Health Administration (OSHA), inquiring about any regulations that OSHA has for protection from microbes. We apologize for the delay in our response to you.
OSHA has only one regulation that specifically discusses microbes in a laboratory setting. This is our Occupational Exposure to Bloodborne Pathogens standard, 29 CFR 1910.1030. While most of the standard addresses exposures which could normally be found in a medical setting, paragraph (e) deals with exposures in an HIV or HBV research laboratory. This paragraph covers special practices, access, warning signs, personal protective equipment, biosafety and training requirements. The text from the standard follows.
(e) HIV and HBV Research Laboratories and Production Facilities.
(e)(1) This paragraph applies to research laboratories and production facilities engaged in the culture, production, concentration, experimentation, and manipulation of HIV and HBV. It does not apply to clinical or diagnostic laboratories engaged solely in the analysis of blood, tissues, or organs. These requirements apply in addition to the other requirements of the standard.
(e)(2) Research laboratories and production facilities shall meet the following criteria:
(i) Standard Microbiological Practices. All regulated waste shall either be incinerated or decontaminated by a method such as autoclaving known to effectively destroy bloodborne pathogens.
(e)(3) HIV and HBV research laboratories shall meet the following criteria:
(ii) Special Practices.
(A) Laboratory doors shall be kept closed when work involving HIV or HBV is in progress.
(B) Contaminated materials that are to be decontaminated at a site away from the work area shall be placed in a durable, leakproof, labeled or color-coded container that is closed before being removed from the work area.
(C) Access to the work area shall be limited to authorized persons. Written policies and procedures shall be established whereby only persons who have been advised of the potential biohazard, who meet any specific entry requirements, and who comply with all entry and exit procedures shall be allowed to enter the work areas and animal rooms.
(D) When other potentially infectious materials or infected animals are present in the work area or containment module, a hazard warning sign incorporating the universal biohazard symbol shall be posted on all access doors. The hazard warning sign shall comply with paragraph (g)(1)(ii) of this standard.
(E) All activities involving other potentially infectious materials shall be conducted in biological safety cabinets or other physical-containment devices within the containment module. No work with these other potentially infectious materials shall be conducted on the open bench.
(F) Laboratory coats, gowns, smocks, uniforms, or other appropriate protective clothing shall be used in the work area and animal rooms. Protective clothing shall not be worn outside of the work area and shall be decontaminated before being laundered.
(G) Special care shall be taken to avoid skin contact with other potentially infectious materials. Gloves shall be worn when handling infected animals and when making hand contact with other potentially infectious materials is unavoidable.
(H) Before disposal all waste from work areas and from animal rooms shall either be incinerated or decontaminated by a method such as autoclaving known to effectively destroy bloodborne pathogens.
(I) Vacuum lines shall be protected with liquid disinfectant traps and high-efficiency particulate air (HEPA) filters or filters of equivalent or superior efficiency and which are checked routinely and maintained or replaced as necessary.
(J) Hypodermic needles and syringes shall be used only for parenteral injection and aspiration of fluids from laboratory animals and diaphragm bottles. Only needle-locking syringes or disposable syringe-needle units (i.e., the needle is integral to the syringe) shall be used for the injection or aspiration of other potentially infectious materials. Extreme caution shall be used when handling needles and syringes. A needle shall not be bent, sheared, replaced in the sheath or guard, or removed from the syringe following use. The needle and syringe shall be promptly placed in a puncture-resistant container and autoclaved or decontaminated before reuse or disposal.
(K) All spills shall be immediately contained and cleaned up by appropriate professional staff or others properly trained and equipped to work with potentially concentrated infectious materials.
(L) A spill or accident that results in an exposure incident shall be immediately reported to the laboratory director or other responsible person.
(M) A biosafety manual shall be prepared or adopted and periodically reviewed and updated at least annually or more often if necessary. Personnel shall be advised of potential hazards, shall be required to read instructions on practices and procedures, and shall be required to follow them.
(iii) Containment Equipment.
(A) Certified biological safety cabinets (Class I, II, or III) or other appropriate combinations of personal protection or physical containment devices, such as special protective clothing, respirators, centrifuge safety cups, sealed centrifuge rotors, and containment caging for animals, shall be used for all activities with other potentially infectious materials that pose a threat of exposure to droplets, splashes, spills, or aerosols.
(B) Biological safety cabinets shall be certified when installed, whenever they are moved and at least annually.
(i) Each laboratory shall contain a facility for hand washing and an eye wash facility which is readily available within the work area.
(e)(4) HIV and HBV production facilities shall meet the following criteria:
(ii) An autoclave for decontamination of regulated waste shall be available.
(i) The work areas shall be separated from areas that are open to unrestricted traffic flow within the building. Passage through two sets of doors shall be the basic requirement for entry into the work area from access corridors or other contiguous areas. Physical separation of the high-containment work area from access corridors or other areas or activities may also be provided by a double-doored clothes-change room (showers may be included), airlock, or other access facility that requires passing through two sets of doors before entering the work area.
(e)(5) Training Requirements.
(ii) The surfaces of doors, walls, floors and ceilings in the work area shall be water resistant so that they can be easily cleaned. Penetrations in these surfaces shall be sealed or capable of being sealed to facilitate decontamination.
(iii) Each work area shall contain a sink for washing hands and a readily available eye wash facility. The sink shall be foot, elbow, or automatically operated and shall be located near the exit door of the work area.
(iv) Access doors to the work area or containment module shall be self-closing.
(v) An autoclave for decontamination of regulated waste shall be available within or as near as possible to the work area.
(vi) A ducted exhaust-air ventilation system shall be provided. This system shall create directional airflow that draws air into the work area through the entry area. The exhaust air shall not be recirculated to any other area of the building, shall be discharged to the outside, and shall be dispersed away from occupied areas and air intakes. The proper direction of the airflow shall be verified (i.e., into the work area).
Additional training requirements for employees in HIV and HBV research laboratories and HIV and HBV production facilities are specified in paragraph (g)(2)(ix).
Most of the material in this section of the regulation was based on the Biosafety Level 3 Guidelines, described in the 1984 National Institute of Health (NIH) Publication "Biosafety in Microbiological and Biomedical Laboratories" and the 1988 Center for Disease Control's (CDC) "Agent Summary Statement for Human Immunodeficiency Virus."
(g)(2)(ix) Additional Initial Training for Employees in HIV and HBV Laboratories and Production Facilities. Employees in HIV or HBV research laboratories and HIV or HBV production facilities shall receive the following initial training in addition to the above training requirements.
(A) The employer shall assure that employees demonstrate proficiency in standard microbiological practices and techniques and in the practices and operations specific to the facility before being allowed to work with HIV or HBV.
(B) The employer shall assure that employees have prior experience in the handling of human pathogens or tissue cultures before working with HIV or HBV.
(C) The employer shall provide a training program to employees who have no prior experience in handling human pathogens. Initial work activities shall not include the handling of infectious agents. A progression of work activities shall be assigned as techniques are learned and proficiency is developed. The employer shall assure that employees participate in work activities involving infectious agents only after proficiency has been demonstrated.
On October 17, 1997, OSHA published a proposed Tuberculosis standard. This proposed standard also proposes coverage of the tuberculosis microbe in both the medical setting and in clinical and research laboratories. Much of the laboratory section of the proposed standard is also based on the 1984 NIH document used with the bloodborne pathogens standard.
Even though OSHA has not finalized a standard for Occupational Exposure to Tuberculosis, we already require employees who are working with patients who have tuberculosis to wear respiratory protection. The respirator must be at least a high efficiency particulate (HEPA) respirator certified by NIOSH under 30 CFR Part 11 or any of the particulate respirators approved under the newer 42 CFR Part 84 (i.e., N95, N99 or N100).
I hope this answers your questions about the OSHA regulations that cover biological hazards in the workplace. Additional information may also be found on our website at :http://www.osha.gov under the Subject Index for Bloodborne Pathogens and Tuberculosis. If you have any further questions you may contact Mr. Craig Moulton in OSHA's Office of Health Compliance Assistance at (202) 693-2190.
Richard E. Fairfax
Directorate of Compliance Programs