Standard Interpretations - Table of Contents
• Standard Number: 1910.1030; 1910.1030(c)(1)(ii); 1910.1030(C)(1)(iv)(B) ; 1910.1030(c)(1))(iv)(A) ; 1910.1030(c)(1)(iv)

January 20, 2004

Mr. Mark B. Evans
Vice President
Strickler Medical Incorporated
503 Libbie Ave, Ste 2C
Richmond, Virginia 23226

Dear Mr. Evans:

Thank you for your November 12, 2003 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP) regarding the applicability of OSHA's bloodborne pathogens standard to small health care facilities (clinics, oncology practices, physician offices, etc.). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question(s) not delineated within your original correspondence. Your questions are restated below, followed by OSHA's response.

Question #1: Are physician offices and clinics required to provide safety-engineered sharp devices and needleless systems to employees? Is there a minimum number of employees that must be employed to be governed by this Act [Needlestick Safety and Prevention Act]?

Reply #1: The Needlestick Safety and Prevention Act directed OSHA to revise its bloodborne pathogens standard [29 CFR 1910.1030]. On January 18, 2001, OSHA published the revised standard, which took effect on April 18, 2001. OSHA's bloodborne pathogens standard, including its 2001 revisions, applies to all employers who have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials (OPIM).

However, workplaces classified in certain Standard Industrial Classification (SIC) code