Clarification of Contaminated Waste Labelling Requirement.

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.

December 13, 1994

MEMORANDUM FOR: FRANK STRANSHEIM

REGIONAL ADMINISTRATOR

FROM: JOHN B. MILES, JR., DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: CLARIFICATION OF CONTAMINATED WASTE LABELLING REQUIREMENT

The purpose of this memorandum is to provide a clarification on labelling of contaminated waste in accordance with your request dated August 22, 1994.

The mandate to use one of two pharmacies and whether or not the time it takes to attend a medical appointment is compensable.

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.

December 7, 1994

Randall U. Mottram Infectious Disease Specialist 10500 Sager Avenue, Suite A Fairfax, VA 22020-2483

Dear Mr. Mottram:

Regulations for Exposure to Bloodborne Pathogens.

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.

December 1, 1994

Mr. Robert Frey 4153 Comanche Drive Jackson, Mississippi 39211

Dear Mr. Frey:

Thank you far your letter of October 13, regarding the Occupational Safety and Health Administration's (OSHA) regulations for Exposure to Bloodborne Pathogens. Your letter has been referred to this office for reply.

HCS as it relates to the guidelines described in OSHA's 1986 publication regarding disposal of hospital wastes contaminated with cytotoxic drugs.

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.

November 21, 1994

[Name Withheld]

Dear [Name Withheld]:

Requesting a written opinion on the disposal of the needle-less Biojector syringe.

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.

November 10, 1994

Mrs. Molly Ruscoe Clinical Representative Bioject Inc. 7620 S.W. Bridgeport Road Portland Oregon 97224

Dear Ms Ruscoe:

This is in response to your letter of August 22, 1994 requesting a written opinion on the disposal of the needle-less Biojector Syringe.

OSHA requirements for sharps containers under the Bloodborne Pathogens Standards.

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.

October 13, 1994

Mr. Andrew Rowjohn Director, Quality Assurance and Regulatory Affairs Becton Dickinson Consumer Products 1 Becton Drive Franklin Lakes, New Jersey 07417-1883

Dear Mr. Rowjohn:

Approval for cut and puncture resistant gloves.

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.

Kilbourn Gordon III, M.D.
Dba Bifid Protection Systems
234 Goldenspur
Orange, California 92669

Dear Dr. Gordon:

This is in response to your letter of March 26, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030., "Occupational Exposure to Bloodborne Pathogens." Specifically, you asked us for approval for cut and puncture resistant gloves.

Bloodborne Pathogens Standard at the Institutions.

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.

May 8, 1996

The Honorable Tim Hutchinson
U.S. House of Representatives
Washington, D.C. 20515

Dear Congressman Hutchinson:

Annual training required by the occupational exposure to bloodborne pathogen standard.

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.

August 31, 1997

Dr. Howard Mertz, Assistant Professor of Medicine
Vanderbilt University Medical Center
1414 The Vanderbilt Clinic
Nashville, TN 37232-5280

Dear Dr. Mertz:

This is in response to your letter dated June 19, 1997, where you expressed a concern about the Occupational Safety and Health Administration's (OSHA) requirement for training. Specifically[,] your letter referenced the annual training required by the Occupational Exposure to Bloodborne Pathogen standard, 29 CFR 1910.1030.

The Bloodborne Pathogen Standard and the Enforcement Procedures for TB.

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.

September 23, 1997

Mr. Chip Darius
Vice President
Holdsworth Associates, Inc.
1224 Mill Street
Post Office Box 503
East Berlin, Cincinnati 06023-0503

Dear Mr. Darius:

This is in response to your letter dated June 27. We apologize for the long delay. Your letter presented specific questions concerning the Occupational Safety and Health Administration's (OSHA) Occupation Exposure to Bloodborne Pathogen Standard and the Enforcement Procedures for Occupational Exposure to Tuberculosis (TB).