Safer medical devices must be selected based on employee feedback and device effectiveness, not Group Purchasing Organizations.

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, 2002

Ms. Audrey Taffet
Manager, Business Development
Terumo Medical Corporation
2101 Cottontail Lane
Somerset, NJ 08873

Dear Ms. Taffet:

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:

Needlestick Safety and Prevention Act and the requirement to include safety-engineered sharps devices in pre-packaged surgical kits or trays.

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.

February 20, 2003

Ms. Wendy Gallart
Senior Marketing Manager
BD Advanced Protection Technologies
Becton, Dickinson and Company
1 Becton Drive
Franklin Lakes, NJ 07417

Dear Ms. Gallart:

Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles.

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 27, 2004

Zeil Rosenberg, M.D., M.P.H.
Worldwide Business Leader and Medical Director
BD Immunization
BD Medical Systems
1 Becton Drive
Franklin Lakes, New Jersey 07417

Dear Dr. Rosenberg:

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:

Clarification from OSHA regarding the use of the NeedleguardTM in a hospital environment.

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.

 

Requirements for safety-engineered sharps for stockpiled pandemic influenza vaccines and pre-filled syringes.

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 2, 2007

Mr. Drew Callison
Medical Surgical Systems
BD Medical
1 Becton Drive
Franklin Lakes, NJ 07417

Dear Mr. Callison:

OSHA's position on the use of Novartis' Fluvirin device.

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.

 

Applicability of the Bloodborne Pathogens standard during transection of the umbilical cord.

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 13, 2012

Mr. Mark W. Bode, CEO
JoeyMedical / The Utopia Group LLC
6279 Tri-Ridge Blvd., Suite 207
Loveland, OH 45140

Dear Mr. Bode: