Application of OSHA's Bloodborne Pathogens standard to digital rectal examinations for rectal foreign bodies

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 22, 2024

Brian C. Weiner, MD, MS, FACP, AGAF
7952 Mansfield Hollow Rd.
Delray Beach, FL 33446

Dear Dr. Weiner:

Is a single-handed scalpel blade removal device an engineering control 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.

February 8, 2023

Dr. Michael Sinnott, MBBS, FACEM, FRACP
Staff and Patient Safety
P.O. Box 5677,
West End,
Brisbane, Queensland, 4101
AUSTRALIA

Dear Dr. Sinnott:

Use of reusable microblading tools in the cosmetic tattoo industry

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 6, 2017

 

Ms. Laurna V. Marika
Director, Body Arts Education Initiative
4346 Augusta Road
Lexington, South Carolina 29073

Dear Ms. Marika:

Engineering controls must be used to prevent needlesticks where feasible.

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 15, 2000

Ms. Carol Vierling
Manager, Regulatory Affairs
Bard Peripheral Technologies
C.R. Bard, Inc.
13183 Harland Dr., NE
Covington, GA 30014

Dear Ms. Vierling:

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:

Labeling requirements under the HAZCOM and Laboratory standards;use of safe needle devices.

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.

NOTE: Citations will be issued to any employer that has not implemented engineering controls where feasible where there is occupational exposure to blood or OPIM.

 

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:

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: