The applicability of OSHA's bloodborne pathogens standards to the use of sharps containers on hospital crash carts.

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 14, 2007

Ms. Selin Hoboy
Corp VP, Environmental, Safety and Health
Stericycle, Inc.
2333 Waukegan Road
Suite 300
Bannockburn, IL 60015

Dear Ms. Hoboy:

Whether diabetics who self-administer at work can dispose of capped insulin syringes in an office trash container.

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 29, 2007

Mr. Keith Dill
15705 Emeline Street
Omaha, NE 68105

Dear Mr. Dill:

OSHA's BBP standard as it relates to laundering of surgical caps contaminated with blood from the operating room.

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 22, 2007

Mr. John Noll, RN, MBA, CNOR
OR Infection Surveillance & CQI
The Reading Hospital and Medical Center
Sixth Avenue and Spruce Street
West Reading, PA 19611

Dear Mr. Noll:

Application of OSHA's Bloodborne Pathogens standard to contractors who clean up blood following accidents.

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 22, 2007

Mr. Dave Middleton
75 Garden Drive
Montgomery, IL 60538

Dear Mr. Middleton:

Whether employees certified in CPR and use of AED's are covered under 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.


April 23, 2007

Mr. Scott Weisman
Pulse America
2511 Montclaire Circle
Weston, FL 33327

Dear Mr. Weisman:

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:

Clarification of PPE requirements for phlebotomists performing venipunctures in hospital setting and/or rural outpatient clinics.

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.


October 26, 2007

Mr. Michael Lonigro
Technical Supervisor
ACL Laboratory
Advocate Good Samaritan Hospital
3815 Highland Avenue, Tower 2; Suite 206
Downers Grove, IL 60515

Dear Mr. Lonigro:

Requirements for the construction of trash receptacles used in operating rooms for the containerization of regulated waste.

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 9, 2007

Mr. William Gavlak
Medical Cost Containment Systems, LLC
P O Box 88327
Atlanta, GA 30356

Dear Mr. Gavlak,

Whether an employee can waive right to have untested blood maintained for 90 days.

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 16, 2008

Ms. Nicole Lepore
National Healthcare Compliance Consultant
6342 Forest Hill Blvd., Suite 205
West Palm Beach, FL 38120

Dear Ms. Lepore: