- Standard Number:
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.
April 13, 1994
Darrell E. Anderson, PE., CIH, CSP
Minnesota Department of Labor and Industry
443 Lafayette Road
St. Paul, Minnesota 55155
Dear Mr. Anderson:
This is in response to your letter of December 17, 1993, requesting clarification of the requirements for disinfection as referenced in CPL 2-2.44C, the directive for the Bloodborne Pathogens standard, 29 CFR 1910.1030. We apologize for the delay in the response. We also thank you for forwarding your decontamination/disinfection information to our staff for review.
In the CDC Morbidity and Mortality Weekly Report (MMWR) dated August 21, 1987, the CDC stated that "disinfectant-detergent formulations registered by EPA can be used for cleaning environmental surfaces, but the actual physical removal of microorganisms by scrubbing is probably at least as important as any antimicrobial effect of the cleaning agent used." The document further states "chemical germicides that are approved for use as "hospital disinfectants" and are tuberculocidal when used at recommended dilutions can be used to decontaminate spills of blood and other body fluids."
Based on this guidance, OSHA has considered the need to use a tuberculocidal germicide for the various activities which a health care worker may encounter. OSHA made the determination to require the methods of disinfection referenced in the compliance directive, CPL 2-2.44C, based on the CDC recommendations as well as industrial hygiene principles to eliminate, to the extent feasible, the source of contamination for workers who may have reasonably anticipated exposure to blood or other potentially infectious materials (OPIM). OSHA believes that the disinfectants referenced in the directive are appropriate and reasonable.
We appreciate your efforts in ensuring that the issues related to appropriate disinfection are brought to our attention.
Sincerely,
H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs