Standard Interpretations - Table of Contents
• Standard Number: 1910.1030; 1910.1030(d)(2)(i); 1910.1030(d)(2)(viii); 1910.1030(d)(3)(i); 1910.1030(d)(4)(ii); 1910.1030(d)(4)(ii)(E)

February 8, 2007

Mr. Thomas Haddock
Manager, Safety and Protection Services
Bay Medical Center
615 North Bonita Avenue
Panama City, FL 32401-3623

Dear Mr. Haddock:

Thank you for your December 8, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter requested information on OSHA standards which addressing safety requirements regarding the washing of surgical instruments by hand. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. We apologize for the delay in addressing your concerns.

Question: A surgeon in an operating room wants to have employees hand wash all instruments after use. Are there any OSHA standards which address safety considerations for washing medical instruments by hand?

Reply: As you may know, the Centers for Disease Control and Prevention (CDC) has developed Guidelines for Handwashing and Hospital Environmental Control, 1985, which include guidance for cleaning reusable medical instruments. The guidelines state: "[a]ll objects to be disinfected or sterilized should first be thoroughly cleaned to remove all organic matter (blood and tissue) and other residue."
1 OSHA does not specifically prohibit the handwashing of instruments that, according to these guidelines, should be pre-cleaned before being disinfected or sterilized. Furthe