Use of engineering and work practice controls during pouring of blood or OPIM.

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.

July 20, 2000

Mr. Jim Dunn
Vice President
Dornach Medical Systems, Inc.
4032 West Riverside Street
Riverside, MO 64150

Dear Mr. Dunn:

Response to the American Academy of Pediatrics regarding the Needlestick Safety and Prevention Act.

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 26, 2001

Steve Berman, MD, FAAP
President
American Academy of Pediatrics (AAP)
141 Northwest Point Blvd
Elk Grove Village, IL 60007-4000

Dear Dr. Berman:

Needle destruction device use as an engineering control for the Bloodbore Pathogens 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.

September 12, 2002


Mr. George R. Salem
Akin, Gump, Strauss, Hauer, & Feld, LLP
Attorney at Law
Robert S. Strauss Building
1333 New Hampshire Avenue NW
Washington, D.C. 20036-1564

Dear Mr. Salem:

Engineering control requirements for allergy and immunization injections.

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.

March 19, 2003

Spencer Atwater, MD
President
Joint Council of Allergy, Asthma and Immunology (JCAAI)
50 N. Brockway Street, Suite 3-3
Palatine, IL 60067

Dear Dr. Atwater:

Employer's responsibility to re-evaluate engineering controls, i.e., safer needle devices, at least annually.

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.

January 20, 2004

Mr. Marty Salanger
Manager of Safety, Policy and Government Relations
BD Advanced Protection Technologies
1 Becton Drive
Franklin Lakes, NJ 07417

Dear Mr. Salanger:

Bloodborne Pathogens Standard application to small healthcare facilities and the annual review of the Exposure Control Plan.

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.

January 20, 2004

Mr. Mark B. Evans
Vice President
Strickler Medical Incorporated
503 Libbie Ave, Ste 2C
Richmond, Virginia 23226

Dear Mr. Evans:

Employer's obligation to assure the accuracy of the sharps injury log.

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.

January 12, 2006

Mr. William A. Hyman
Professor
Texas A&M University
Department of Environmental Engineering
233 Zachry Engineering Center
3120 TAMU
College Station, TX 77843-3120

Dear Mr. Hyman:

Use of passing trays and single-handed scalpel blade remover in a surgical setting.

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 22, 2005

Dr. Michael Sinnott, MBBS, FACEM, FRACP
PO Box 5677
West End QLD 4101
Australia

Dear Dr. Sinnott:

Limiting factors for implementing the use of engineering controls, i.e., safety scalpels, under the Bloodborne Pathogens 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.

September 1, 2004

Ms. Debbie Eckard
Product Manager
American Safety Razor Company
One Razor Blade Lane
Verona, VA 24482

Dear Ms. Eckard:

The use of safety-engineered devices and work practice controls in operating rooms; hospital responsibility to protect independent practitioners under BBP 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.

January 18, 2007

Mr. Erik Frederick
Director of Safety
Baptist Medical Center
111 Dallas Street
San Antonio, Texas 78224

Dear Mr. Frederick: