Standard Interpretations - Table of Contents
• Standard Number: 1910.1030(c)(1)(iv); 1910.1030(c)(1)(v); 1910.1030(c)(1)(iv)(B); 1910.1030(d)(2)(i)


September 1, 2004

Ms. Debbie Eckard
Product Manager
American Safety Razor Company
One Razor Blade Lane
Verona, VA 24482

Dear Ms. Eckard:

Thank you for your May 7, 2004 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter addresses several issues which are restated below, followed by OSHA's response. 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.

Question 1: Do healthcare facilities need to use reengineered safety scalpels to be in compliance with the bloodborne pathogens regulations, or can they simply evaluate?

Reply 1: OSHA's bloodborne pathogens standard at 29 CFR 1910.1030(c)(1)(iv) requires employers to evaluate safer medical devices to eliminate or minimize employee exposure to blood or other potentially infectious materials (OPIM). Employers must solicit input from non-managerial employees in the selection process [29 CFR 1910.1030(c)(1)(v)]. Engineering controls, including safety scalpels, must be implemented where their use is feasible [29 CFR 1910.1030(d)(2)(i)].

Question 2: If not, under what circumstances may they choose not to employ safety scalpels?

Reply 2: OSHA recognizes that no one medical device is appropriate for use in all circumstances and that it is important to safeguard both patients and employees during medical and surgical procedures. If