Recapping of contaminated needles used in body piercing.

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 19, 2003

David Vidra, CLPN, MA
President
Health Educators, Inc.
2710 Detroit Avenue, Lower Level
Cleveland, OH 44113

Dear Mr. Vidra:

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:

"Freehand" piercing without the use of forceps or other engineering controls violates 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.

December 8, 2005

Mr. David Vidra, CPLN, MA
President
Mr. Kris Lachance-Peters
Vice President
Health Educators, Inc.
515 E. Grand River Avenue, Suite F
East Lansing, MI 48823

Dear Mr. Vidra & Mr. Lachance-Peters:

Applicability of the bloodborne pathogens standard to persons who self-administer injectable medications.

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 6, 2005

Mr. William M. Teringo
President
PDMP, Inc.
105 Loudoun Street, S.W.
Leesburg, VA 20175

Dear Mr. Teringo:

Definition of contaminated sharps; engineering controls and good work practice controls must be implemented; ECP must be reviewed 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.

June 3, 2005

Mr. Craig Voellmicke
Product Manager
BD Medical
MC 208
1 Becton Drive
Franklin Lakes, NJ 07417

Dear Mr. Voellmicke:

Containment and disposal requirements for disposable razors used in long-term health care facilities for personal grooming.

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 28, 2005

Mr. Frank A. White
ORC Worldwide
1800 K Street, NW
Suite 810
Washington, DC 20006-2226

Dear Mr. White:

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:

Whether shielding is required when removing Becton Dickinson's blood tubes with a Hemoguard® closure.

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 29, 2007

Ms. Linda King, MSOH, MT(ASCP)SC
Quality Assurance Analyst/Safety Officer
Mercy Integrated Laboratories
2222 Cherry Street
Toledo, Ohio 43608

Dear Ms. King:

Whether the BD SmartSlip™ is an acceptable safety-engineered device under 1910.1030.

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.


June 21, 2007

Ms. Marcia Fusilli
Sr. Product Manager — Safety Hypodermic
BD Medical Surgical Systems
1 Becton Drive
Franklin Lakes, NJ 07417

Dear Ms. Fusilli: