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Standard Interpretations - Table of Contents
• Standard Number: 1910.1030; 1910.1030(d)(2)(i); 1910.1030(d)(2)(viii); 1910.1030(d)(3)(i); 1910.1030(d)(4)(ii); 1910.1030(d)(4)(ii)(E)

February 8, 2007

Mr. Thomas Haddock
Manager, Safety and Protection Services
Bay Medical Center
615 North Bonita Avenue
Panama City, FL 32401-3623

Dear Mr. Haddock:

Thank you for your December 8, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter requested information on OSHA standards which addressing safety requirements regarding the washing of surgical instruments by hand. 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. We apologize for the delay in addressing your concerns.

Question: A surgeon in an operating room wants to have employees hand wash all instruments after use. Are there any OSHA standards which address safety considerations for washing medical instruments by hand?

Reply: As you may know, the Centers for Disease Control and Prevention (CDC) has developed Guidelines for Handwashing and Hospital Environmental Control, 1985, which include guidance for cleaning reusable medical instruments. The guidelines state: "[a]ll objects to be disinfected or sterilized should first be thoroughly cleaned to remove all organic matter (blood and tissue) and other residue."
1 OSHA does not specifically prohibit the handwashing of instruments that, according to these guidelines, should be pre-cleaned before being disinfected or sterilized. Furthermore, OSHA's bloodborne pathogens standard (BBP), 29 CFR 1910.1030, which provides protection for employees from exposure to blood or other infectious materials (OPIM), in general, requires employers to establish appropriate cleaning and decontaminating procedures for all contaminated equipment. The standard, at paragraph (d)(4)(ii), requires that "All equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials."

However, according to paragraph (d)(2)(i) of OSHA's BBP standard, where engineering and work practice controls will reduce employee exposure either by removing, eliminating, or isolating the hazard, they must be used. This would include the use of existing, feasible, commercially available engineering controls, such as the use of ultrasonic cleaners. In circumstances where ultrasonic cleaners or other engineering control measures are deemed infeasible, the implementation of work practices, such as the use of long-handled brushes for physically removing organic material on reusable sharps is expected in order to reduce the potential for employee exposure to blood or OPIM on contaminated sharp instruments.

Additionally, employers must provide personal protective equipment when the use of engineering controls and work practices does not eliminate the hazard. As an example, employers who assign employees the task of cleaning medical instruments by hand must evaluate the task and provide impervious gloves for additional protection against cuts or lacerations from sharp objects [29 CFR 1910.1030(d)(3)(i)].

Regarding the storage and reprocessing of contaminated reusable sharp instruments, 29 CFR 1910.1030(d)(2)(viii) requires: "Immediately or as soon as possible after use, contaminated reusable sharps shall be placed in appropriate containers until properly reprocessed". Additionally, 1910.1030(d)(4)(ii)(E) provides: "Reusable sharps that are contaminated with blood or other potentially infectious materials shall not be stored or processed in a manner that requires employees to reach by hand into the containers where these sharps have been placed."

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.


Richard E. Fairfax, Director
Directorate of Enforcement Programs

1 Guideline for Handwashing and Hospital Environmental Control, 1985. Julia S. Garner; Matin S.Favero, Hospital Infections Program Center for Infectious Diseases, Centers for Disease Control and Prevention. p.9.
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Standard Interpretations - Table of Contents

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