osha_letters.html

OSHA Bloodborne Pathogens Standard:
selected standard interpretation letters since 2000


Background: OSHA "standard interpretations" letters are written in response to inquiries from employers, industry, and other stakeholders seeking guidance about specific issues that arise in applying and implementing a standard in the workplace.

The standard interpretation letters below address issues related to the bloodborne pathogens standard (BPS), particularly ones that arose after the passage of the Needlestick Safety and Prevention Act in 2000 and the mandated revision of the BPS that followed in 2001. More information about standard interpretations is available from OSHA's Directorate of Enforcement Programs.

  • Note: This is not a complete list of OSHA interpretation letters on the bloodborne pathogens standard. For a comprehensive list, go here
  • For a list organized by year, click here.
  • For PDF of list, click here .

List in alphabetical order* (title of letter is given, followed by the section of the BPS letter being interpreted, and date letter was issued):

Acceptable time lapse for "annual" training. [1910.1030(g)(2)(v) - 01/24/2007]

Applicability of the bloodborne pathogens standard to persons who self-administer injectable medications. [1910.1030(b) - 09/06/2005]

Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles. [1910.1030 - 05/27/2004]

Bloodborne Pathogens Standard application to small healthcare facilities and the annual review of the Exposure Control Plan. [1910.1030 - 01/20/2004]

Clarification of PPE requirements for phlebotomists performing venipunctures in hospital setting and/or rural outpatient clinics. [1910.1030 - 10/26/2007]

Clarification of PPE requirements for phlebotomists performing venipunctures in hospital setting and/or rural outpatient clinics. [1910.1030(g)(2)(vii)(E) - 10/26/2007]

Clarification of the use and selection of BBP safety devices. [1910.1030 - 05/05/2008]

Clarification on trainer requirements and access to trainer under OSHA's bloodborne pathogens standard. [1910.1030 - 01/17/2008]

Compliance with the OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030. [1910.1030 - 02/27/2009]

Definition of contaminated sharps; engineering controls and good work practice controls must be implemented; ECP must be reviewed annually. [1910.1030(c)(1) - 06/03/2005]

Disposal of blood and other potentially infectious materials (OPIM). [1910.1030 - 06/02/2009]

Employee access to needlestick and contaminated sharps injury log requirements. [1910.1030 - 03/14/2003]

Employer's obligation to assure the accuracy of the sharps injury log. [1910.1030 - 01/12/2006]

Employer's responsibility to re-evaluate engineering controls, i.e., safer needle devices, at least annually. [1910.1030 - 01/20/2004]

Engineering control requirements for allergy and immunization injections. [1910.1030 - 03/19/2003]

Engineering controls must be used to prevent needlesticks where feasible. [1910.1030(d)(2)(viii) - 12/15/2000]

Evaluation of safer medical devices and the use of therapeutic radiopharmaceuticals. [1910.1030 - 08/17/2001]

Evaluation of sutureless catheter securement devices to prevent needlestick hazards. [1910.1030 - 01/23/2003]

Limiting factors for implementing the use of engineering controls, i.e., safety scalpels, under the Bloodborne Pathogens standard. [1910.1030(c)(1)(iv)(B) - 09/01/2004]

Means of reducing needlestick exposure hazards. [1910.1030(d)(2) - 06/27/2001]

Needle removal procedures for situations where other methods of disposal are infeasible or required by a specific procedure. [1910.1030(d)(2)(vii)(A) - 12/09/2004]

Needlestick Safety and Prevention Act amplifies the requirements to use safer needle devices. [1910.1030(d)(2) - 05/17/2001]

Needlestick Safety and Prevention Act and the requirement to include safety-engineered sharps devices in pre-packaged surgical kits or trays. [1910.1030 - 02/20/2003]

OSHA has no specific standard on autoclaving used medical instruments. [1910.1030 - 09/03/2004]

OSHA's outreach effort to educate employers on the Needlestick safety and Prevention Act requirements. [1910.1030 - 09/03/2003]

OSHA's position on the use of Novartis' Fluvirin® device. [1910.1030 - 11/24/2008]

OSHA's position on the use of Q104 needle removal device. [1910.1030 - 09/25/2008]

OSHA's position on the use of fingers or a two-handed procedure with a hemostat to remove scalpel blades. [1910.1030 - 11/21/2008]

OSHA's position on the use of lancets or lancing devices without safety-engineered features for finger prick blood sampling in the workplace. [1910.1030 - 09/09/2008]

OSHA training Standards Policy Statement. [1910.1030(g)(2)(vii)(N) - 04/17/2007]

Placement of sharps containers and requirement to ensure they are maintained in an upright position. [1910.1030 - 04/18/2008]

Plasma-derived products are considered "blood" within the meaning of the Bloodborne Pathogens Standard. [1910.1030(a) - 12/27/2002]

Requirements for safety-engineered sharps for stockpiled pandemic influenza vaccines and pre-filled syringes. [1910.1030 - 03/02/2007]

Response to the American Academy of Pediatrics regarding the Needlestick Safety and Prevention Act. [1910.1030(d)(2)(i) - 11/26/2001]

Re-use of blood tube holders. [1910.1030(d)(2)(vii)(A) - 06/12/2002]

Safer medical devices must be selected based on employee feedback and device effectiveness, not Group Purchasing Organizations. [1910.1030 - 11/21/2002]

Safety considerations for handwashing of medical instruments. [1910.1030(d)(4)(ii)(E) - 02/08/2007]

Sharps injury logs are intended to track departments, devices, and/or procedures causing injuries, not injured employees. [1910.1030 - 12/03/2002]

Standard syringes may still be used in certain situations. [1910.1030(d)(2) - 08/24/2001]

The BBP standard applicability to home health care service workers. [1910.1030 - 05/04/2000]

The applicability of OSHA's bloodborne pathogens standards to the use of sharps containers on hospital crash carts. [1910.1030 - 06/14/2007]

The use of safety-engineered devices and work practice controls in operating rooms; hospital responsibility to protect independent practitioners under BBP standard. [1910.1030 - 01/18/2007]

Use of engineering and work practice controls during pouring of blood or OPIM. [1910.1030(d)(4)(iii) - 02/09/2001]

Use of passing trays and single-handed scalpel blade remover in a surgical setting. [1910.1030 - 12/22/2005]

Use of rapid HIV antibody testing on a source individual after an exposure incident. [1910.1030 - 01/08/2007]

Whether dental anesthetic carpules are considered to be "contaminated sharps" or "regulated waste". [1910.1030 - 01/09/2007]

 

OSHA standard interpretation letters, by year
(starting with most recent)

2009

2/27/09: Compliance with the OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030. [1910.1030]

6/02/09: Disposal of blood and other potentially infectious materials (OPIM). [1910.1030]

2008

1/17/08: Clarification on trainer requirements and access to trainer under OSHA's bloodborne pathogens standard. [1910.1030]

4/18/2008: Placement of sharps containers and requirement to ensure they are maintained in an upright position. [1910.1030]

5/05/08: Clarification of the use and selection of BBP safety devices. [1910.1030]

9/09/08: OSHA's position on the use of lancets or lancing devices without safety-engineered features for finger prick blood sampling in the workplace. [1910.1030]

9/25/08: OSHA's position on the use of Q104 needle removal device. [1910.1030]

11/21/08: OSHA's position on the use of fingers or a two-handed procedure with a hemostat to remove scalpel blades. [1910.1030]

11/24/08: OSHA's position on the use of Novartis' Fluvirin® device. [1910.1030]

2007

1/08/07: Use of rapid HIV antibody testing on a source individual after an exposure incident. [1910.1030]

1/09/07: Whether dental anesthetic carpules are considered to be "contaminated sharps" or "regulated waste". [1910.1030]

1/18/07: The use of safety-engineered devices and work practice controls in operating rooms; hospital responsibility to protect independent practitioners under BBP standard. [1910.1030]

1/24/07: Acceptable time lapse for "annual" training. [1910.1030(g)(2)(v)]

2/08/07: Safety considerations for handwashing of medical instruments. [1910.1030(d)(4)(ii)(E)]

3/02/07: Requirements for safety-engineered sharps for stockpiled pandemic influenza vaccines and pre-filled syringes. [1910.1030]

4/17/07: OSHA training Standards Policy Statement. [1910.1030(g)(2)(vii)(N)]

6/14/07: The applicability of OSHA's bloodborne pathogens standards to the use of sharps containers on hospital crash carts. [1910.1030]

10/26/07: Clarification of PPE requirements for phlebotomists performing venipunctures in hospital setting and/or rural outpatient clinics. [1910.1030]

2006

1/12/06: Employer's obligation to assure the accuracy of the sharps injury log. [1910.1030]

2005

6/03/05: Definition of contaminated sharps; engineering controls and good work practice controls must be implemented; ECP must be reviewed annually. [1910.1030(c)(1)]

9/6/05: Applicability of the bloodborne pathogens standard to persons who self-administer injectable medications. [1910.1030(b)]

12/22/05: Use of passing trays and single-handed scalpel blade remover in a surgical setting. [1910.1030]

2004

1/20/04: Employer's responsibility to re-evaluate engineering controls, i.e., safer needle devices, at least annually. [1910.1030]

01/20/04: Bloodborne Pathogens Standard application to small healthcare facilities and the annual review of the Exposure Control Plan. [1910.1030]

5/27/04: Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles. [1910.1030]

9/01/04: Limiting factors for implementing the use of engineering controls, i.e., safety scalpels, under the Bloodborne Pathogens standard. [1910.1030(c)(1)(iv)(B)]

9/03/04: OSHA has no specific standard on autoclaving used medical instruments. [1910.1030]

12/09/04: Needle removal procedures for situations where other methods of disposal are infeasible or required by a specific procedure. [1910.1030(d)(2)(vii)(A)]

2003

1/23/03:   Evaluation of sutureless catheter securement devices to prevent needlestick hazards. [1910.1030]

2/20/03: Needlestick Safety and Prevention Act and the requirement to include safety-engineered sharps devices in pre-packaged surgical kits or trays. [1910.1030]

3/14/03: Employee access to needlestick and contaminated sharps injury log requirements. [1910.1030]

3/19/03: Engineering control requirements for allergy and immunization injections. [1910.1030]

9/03/03: OSHA's outreach effort to educate employers on the Needlestick safety and Prevention Act requirements. [1910.1030]

2002

6/12/02: Re-use of blood tube holders. [1910.1030(d)(2)(vii)(A)]

11/21/02: Safer medical devices must be selected based on employee feedback and device effectiveness, not Group Purchasing Organizations. [1910.1030]

12/03/02: Sharps injury logs are intended to track departments, devices, and/or procedures causing injuries, not injured employees. [1910.1030]

12/27/02: Plasma-derived products are considered "blood" within the meaning of the Bloodborne Pathogens Standard. [1910.1030(a)]

2001

2/09/01: Use of engineering and work practice controls during pouring of blood or OPIM. [1910.1030(d)(4)(iii)]

5/17/01: Needlestick Safety and Prevention Act amplifies the requirements to use safer needle devices. [1910.1030(d)(2]

6/27/01: Means of reducing needlestick exposure hazards. [1910.1030(d)(2)]

8/17/01: Evaluation of safer medical devices and the use of therapeutic radiopharmaceuticals. [1910.1030]

8/24/01: Standard syringes may still be used in certain situations. [1910.1030(d)(2)]

11/26/01: Response to the American Academy of Pediatrics regarding the Needlestick Safety and Prevention Act. [1910.1030(d)(2)(i)]

2000

5/04/00: The BBP standard applicability to home health care service workers. [1910.1030]

12/15/00: Engineering controls must be used to prevent needlesticks where feasible. [1910.1030(d)(2)(viii)]