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.

August 12, 1992

Brian P. Moore, M.D.
Appleton Medical Center
1818 North Meade St.
Appleton, WI 54911

Dear Dr. Moore:

This is in response to your letter of June 1, regarding the Occupational Safety and Health Administration (OSHA) standard on "Occupational Exposure to Bloodborne Pathogens," 29 CFR 1910.1030, section (d)(2)(v). Specifically, you requested that OSHA "reconsider this section and waive the requirement for hand washing when a phlebotomist removes gloves between patients and there is no visible contamination of the gloves with blood or OPIM."

Section (d)(2)(v) of the standard very specifically requires handwashing after removal of gloves or other personal protective equipment. OSHA believes the benefits of this practice far outweigh the concerns you presented of excessive handwashing and delays in performing procedures. Please note that this requirement was presented to, and supported by, a number of commentors to the public record following publication of the proposed regulation in May, 1989.

Please bear in mind, however, that while it is sound public health policy to do so, OSHA does not have a requirement that gloves be changed between patients. We hope this information is responsive to your concerns.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs