Definition of "article" under the HCS in reference to medical supplies and 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.
January 5, 1990
Mr. Robert C. Wilbur
Vice President for Government Relations
Health Industry Distributors Association
1101 Connecticut Avenue, N.W., Suite 700
Washington, D.C. 20036
Dear Mr. Wilbur: