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 15, 2002

 

 

MEMORANDUM FOR: CINDY A. COE
REGIONAL ADMINISTRATOR
 
FROM: RICHARD E. FAIRFAX, DIRECTOR
DIRECTORATE OF ENFORCEMENT PROGRAMS
 
SUBJECT: Response to Interpretation Request for Application of the Bloodborne Pathogens Standard to Veterinary Clinics

 


In response to your July 23, 2002 request for an interpretation of the application of the bloodborne pathogens standard (29 CFR 1910.1030) to veterinary clinics, we hope this memorandum serves your needs. Your interpretation of the standard stated in your incoming memorandum is correct. The standard generally only applies to occupational exposures to human blood, blood components, and other potentially infectious materials (OPIM), unless the blood is known to be infected with the human immunodeficiency virus (HIV) or hepatitis B virus (HBV).

While there may be a potential risk of transmission of bloodborne diseases from animals to humans, it was decided during rulemaking that the general sections of the standard would apply only to human-human exposures, unless the animal blood is used for research and is known to be infected with HIV or HBV. In the preamble, under the discussion for the definition of other potentially infectious materials (OPIM), it states, "the current definition includes the blood of animals experimentally infected with HIV or HBV. It would not normally include the blood from companion animals (pets), other domestic animals, animals in zoos, or research animals not infected with HIV or HBV. The record does not contain the information necessary to determine whether animal blood in these circumstances presents a significant occupational risk." (Federal Register, Vol. 56, No. 235, p. 64103)

If an employee is injured with a medical device used in veterinary medicine/research, it would be required to be placed in an appropriate regulated waste sharps container that adheres to the requirements set forth in paragraph 1910.1030(d)(4)(iii), as it is contaminated with human blood or OPIM. In preparation for an accidental needlestick, sharps containers should be conveniently and safely located in any facility where medical device sharps are used.

While OSHA’s jurisdiction is limited to only animal blood known to be infected with HIV or HBV or other pathogen for research purposes, other federal, state, or local authorities may have regulations in place that do apply to the proper disposal of waste and contaminated sharps used for performing procedures on animals in veterinary settings. Such agencies may include the US Department of Agriculture (USDA), state or county Departments of Health, state or county Departments of Public Health, the Centers for Disease Control and Prevention (CDC), and the Environmental Protection Agency (EPA).

A valuable resource for addressing biohazard exposures in veterinary settings is the American Veterinary Medical Association (AVMA). In a February 1994 journal article (JAVMA, Vol. 204, No. 3), AVMA recommends voluntary compliance with OSHA’s bloodborne pathogens standard in order to best protect employees working in veterinary or other animal settings. This article clearly identifies exposure to animal blood as a potential risk for the transmission of diseases. Also, the Centers for Disease Control and Prevention (CDC) offer information on good work practices when working with non-human primates and other animals. Information from the CDC is available at www.cdc.gov.

Because a potential risk exists for the transmission of diseases from animals to humans and because the OSHA standard does not cover all exposures to animal blood, it may be important to employers and employees working in facilities with animals to practice the principles of general industrial hygiene, including the institution of a hierarchy of controls. Standard precautions, good work practices, the implementation of engineering controls, and the use of personal protective equipment are means to preventoccupational exposures to animal blood and OPIM.

We hope you find this information helpful. If you have any further questions, feel free to contact the Office of Health Enforcement at (202) 693-2190.