Standard Interpretations - Table of Contents
• Standard Number: 1910.1030; 1910.1030(d)(2)(vii)(A); 1910.1030(d)(2)(vii)(B)


November 21, 2008

Dr. Michael Sinnott
Qlicksmart Pty Ltd.
PO Box 5677
West End
Brisbane 4101
Australia

Dear Dr. Sinnott:

Thank you for your August 31, 2008 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). You have concerns about safe use of scalpels in the operating room. 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. For clarification, your specific questions are paraphrased below, followed by OSHA's responses. We apologize for the delay in addressing your concerns.

Question 1: Does the use of fingers to remove used scalpel blades meet the requirements of OSHA's bloodborne pathogens standards (29 CFR 1910.1030)?

Reply 1: No. OSHA's bloodborne pathogens standard prohibits the bending, recapping or removal of a contaminated needle or other contaminated sharp unless the "employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure." [29 CFR 1910.1030(d)(2)(vii)(A)]. Therefore, using fingers to remove a used scalpel blade does not meet the requirements of the standard. In situations where an employer has demonstrated that the use of a scalpel with a reusable handle is required by a specific medical or dental procedure or that no alternative is feasible, blade removal must be accomplished through the use of a mechanical device or a one-handed technique [29 CFR 1910.1030(d)(2)(vii)(B)].

Question 2: Some facilities use a two-handed procedure with a hemostat as a mechanical device to remove scalpel blades. Does the use of a two-handed procedure, such as use of hemostats, to remove used scalpel blades, meet the requirements of OSHA's bloodborne pathogens standards (29 CFR 1910.1030)?

Reply 2: H