June 10, 1994

Mr. Robert L. Bays, Sr.
Director of Technical Support
Huntington Laboratories, Inc.
970 E. Tipton
Huntington, Indiana 46750

Dear Mr. Bays:

This is in response to your letter of November 5, 1993, requesting clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." We apologize for the delay in this response.

Specifically, you inquired about the decontamination of a plush carpet surface after a blood or other potentially infectious material (OPIM) spill has occurred. In our November 16, 1992 letter to Ms. Gwendolyn Mayo of Mayo Aviation, we stated "the employer may be able to satisfactorily accomplish the decontamination of plush carpets." We were incorrect in making this statement. We apologize for any confusion this statement may have caused. OSHA does not have any evidence to support whether decontamination of plush carpets is possible; it is our opinion that carpeted surfaces cannot be routinely decontaminated. However, under normal circumstances, carpeted surfaces are located in areas where there is minimal exposure from dermal contact, therefore, employers are expected to make a reasonable effort to clean and sanitize carpeting and soft plush surfaces with carpet detergent/cleaner products. In the case of extended patient transport flight aircraft, elimination or minimization of soft plush surfaces, in accordance with FAA regulations, would be beneficial from the standpoint of complying with this requirement of the standard.

OSHA requires that equipment and surfaces be cleaned and disinfected after contact with blood or OPIM. It is the employer's responsibility to determine and implement an appropriate written schedule for cleaning and the method of decontamination based on the location within a facility, the type of surface to be cleaned, the type of spill present, and the tasks or procedures being performed in the area.

We hope this information is responsive to your concerns and thank you for your interest in safety and health.

Sincerely,

H. Berrien Zettler, Deputy Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]

November 5, 1993

OSHA
Roger Clark, Director
[Directorate of Enforcement Programs]
Department of Labor, OSHA
200 Constitution Ave., [Room N3119]
Washington, D.C. 20210

Dear Mr. Clark:

Subject: Blood and/or OPIM on carpets.

I read with interest your letter to Ms. Gwendolyn O. Mayo, President, Mayo Aviation, P. O. Box 38444, Denver, Co 80238 (Attached) regarding the "decontamination of plush surfaces" per your letter:

"The final portion of your letter requests information on the decontamination of plush surfaces, easy maintenance flooring/side panel materials that meet FAA regulations, and recommendations for aircraft utilizing quick-change interiors. As stated in OSHA Instruction CPL 2-2.44C, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard," a product must be registered by the Environmental Protection Agency (EPA) as a tuberculocidal disinfectant in order for OSHA to consider it to be effective in the cleanup of a contaminated item or surface. A solution of 5.25 percent sodium hypochlorite (household bleach) diluted between 1:10 and 1;100 with water is also acceptable for the cleanup of contaminated items or surfaces.

We can make no specific recommendations regarding flooring/side panel materials and quick-change interiors as we are not familiar with FAA regulations in this area. The standard requires the employer to maintain the worksite in a clean and sanitary condition. The employer may be able to satisfactorily accomplish the decontamination of plush surfaces (Bold is mine.) Logically, however, non-absorbent firm surfaces are more easily cleaned and decontaminated. Elimination or minimization of soft plush surfaces (carpeting, velour seats/side panels, etc.) wherever possible would be beneficial from the standpoint of complying with this requirement of the standard. This would include quick-change interiors where plush surfaces are removable and able to be replaced with smooth firm surfaces."

The OSHA Bloodborne standard (Federal Register/Vol. 56/No. 235/Friday December 6, 1991/Rules and Regulations P. 4175) defines contamination as "the presence or the reasonable anticipated presence of blood or other potentially infectious materials." The definition of decontamination means "the use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item to a point where they are no longer capable of transmitting infections particles and the surface or item is rendered safe for handling, use, or disposal."

Now, here is the problem, there is no disinfectant on the market that can claim disinfection ("decontamination") of a "plush surface" because the EPA has not accepted a test protocol for the disinfection of carpets. The disinfectants on the market [have] EPA registered claims for "hard surfaces", not plush/carpet surfaces.

Please refer to the bottom of page one (1) and the top of page two (2) of the enclosed letter from Roger L. Anderson Ph.D. of the Hospital Environment Laboratory Branch, Hospital Infectious Program, National Center for Infectious Diseases.

"Blood or other body fluids spilled on carpets should be promptly and carefully cleaned, and disinfected. If such fluids are allowed to stand for a period of time and harden or "set up", the removal of these dried fluid materials will be difficult. Concerning the treatment of carpets, the highest grade of antimicrobial activity possible is "sanitizing," which simply reduces the total number of bacteria present. There are no Environmental Protection Agency-registered products for the disinfection of carpets, not even bleach-type products. Neither are there any EPA-registered products for sanitizing commercial and institutional carpets. Some carpet fabrics are "dye-fast" and can withstand exposure to 1:10 to 1:100 dilutions of sodium hypochlorite (household bleach). I would suggest that you contact the carpet manufacturer to first determine if the carpet has "dye-fast" properties and then if bleach solutions could be used for disinfection." (Bold is mine.)

OSHA says under [1910.1030(d)(4)(ii)(A)] (Federal Register/Vol. 56/No. 235/Friday December 6, 1991/Rules and Regulations P. 64177) that "contaminated work surfaces shall be decontaminated with an appropriate disinfectant. In your letter to Ms Mayo on page two(2), middle paragraph, you refer to the CPL 2-2-44C definition of appropriate disinfectant, a "Tuberculocidal disinfectant or 5.25 percent sodium hypochlorite (household bleach) diluted between 1:10 and 1:100 with water."

Again, neither one can claim disinfection on a plush/carpet surface. They are hard surface disinfectants. Therefore what do we do when a surface cannot be decontaminated (by OSHA's definition)?

Here we are faced by "Reality and Legality." You have a blood or OPIM spill on carpet. In reality you MAY be able through absorption, shampooing, then followed by extraction with a tuberculocidal disinfectant to decontaminate the carpet. But you DON'T have a legal leg to stand on! Nowhere on the label of the disinfectant will there be a claim or procedure for the disinfection of plush/carpet surfaces.

What is OSHA's response to a customer when faced (by law -- OSHA's) with a Blood or OPIM spill on a plush/carpet surface? The customer can not claim decontamination. There IS NO label claim.

I appreciate your help in this matter. WE have had many of our customers ask this question. If the carpet can NOT be disinfected (decontaminated), then must it be "pulled up" and a hard surface that can be decontaminated be installed.

Sincerely

HUNTINGTON LABORATORIES, INC.

Robert L. Bays
Sr. Director
Technical Support

RLB:mef

December 4, 1992

Mr. Robert Bays
Director, Technical Services
Huntington Laboratories, Inc.
Huntington, Indiana 46750

Dear Mr. Bays:

Thank you for your call on December 3 concerning the cleaning and disinfection of hospital carpets. Enclosed are several articles on carpets that may be of help and interest to you. Hopefully, some of your questions will be answered.

Results from our studies in hospitals indicate that carpets become highly contaminated with microorganisms as time passes and thus might present an infection potential to the hospital. To date, there is no epidemiological proof to show that carpeted floors have or have not caused patient infections or produced an increased infection rate within hospitals. No data are available regarding the incidence of infections in hospitals with carpeting as compared with the infections in hospitals with other floor coverings.

Carpets installed in areas where spillage of liquids may occur pose another problem -- maintenance, since spillage may cause staining and spotting of carpet materials. Carpets, however, may contain much higher levels of microbial contamination than
hard-surfaced flooring and can be difficult to keep clean in areas of heavy soiling or spillage; therefore, appropriate cleaning and maintenance procedures are indicated. The manufacturer of carpeting should have a maintenance manual available to the hospital to indicate the appropriate cleaning and disinfection procedures for the various and diverse spills that can occur on carpet surfaces.

Presently in the hospital, routine vacuuming and an occasional dry or wet shampooing of carpets are the only practical housekeeping procedures used on this type of floor covering. When using dry vacuuming with carpet materials, it would be imperative that the machine contain high efficiency filters (external or internal) that would filter out bacteria and dust particles down to 0.3 micron and below. The vacuum should also be designed so it will not resuspend dust by directing high-velocity exhaust air at contaminated surfaces, including inputs. This would certainly eliminate the hazard of airborne contamination from non-filtered machines in patient-care areas. A deep-steam cleaning procedure using steam under pressure is available, but its use is directed more toward commercial carpet installed in hotels, restaurants, etc. To my knowledge, there are no published reports or articles (i.e., documented in a reputable scientific journal) comparing antimicrobial-treated carpets with non-treated carpets in a similar hospital setting.

To date, no information is available on which housekeeping programs produce acceptable low levels of microbiological life in hospital carpeting. There are no "germicidal" rug shampoos now available on the market, although several companies are doing research along this line. The effects of organic materials that may be present in carpet material, e.g., dirt, dust, skin sloughs, fecal material, urine, part of the carpet itself, etc., might make the microbicidal action of rug "germicides" less than desirable.

Blood or other body fluids spilled on carpets should be promptly and carefully cleaned, and disinfected. If such fluids are allowed to stand for a period of time and harden or "set up," the removal of these dried fluid materials will be difficult. Concerning the treatment of carpets, the highest grade of antimicrobial activity possible is "sanitizing," which simply reduces the total number of bacteria present. There are no Environmental Protection Agency-registered products for the disinfection of carpets, not even bleach-type products. Neither are there any EPA-registered products for sanitizing commercial and institutional carpets. Some carpet fabrics are "dye-fast" and can withstand exposure to 1:10 to 1:100 dilutions of sodium hypochlorite (household bleach). I would suggest that you contact the carpet manufacturer to first determine if the carpet has "dye-fast" properties and then if bleach solutions could be used for disinfection.

The potential fire and smoke hazards of carpets and carpet pad materials cannot be overemphasized. The Ohio nursing home fire (Hospitals (J.A.H.A.) 44 (Mar. 1): 28a-28d, 1970) in which 32 patients died illustrates this point; carpeting and its foam rubber backing contributed to the rapid spread of the fire and to the heavy, dense, black smoke that hampered rescue operations."

[The] installation of carpets in hospitals is strictly an administrative decision. Each institution must look at its own needs and finances before making that commitment. Obvious things to scrutinize would include: 1) does the hospital or other health-care facility really need or want carpeting in all patient-care areas, including high risk areas?; 2) the total costs (i.e., initial installation, maintenance, and replacement costs) of carpeting vs. hard-surface flooring; and 3) the development of appropriate cleaning, maintenance, and disinfection procedures once the carpet materials have been installed. I hope this information will be of some help to you. With best regards.

Sincerely yours,

Roger L. Anderson, Ph.D.
Scientist Director
Hospital Environment Laboratory Branch
Hospital Infections Program
National Center for Infectious Diseases

Enclosures

November 16, 1992

Ms. Gwendolyn O. Mayo
President
Mayo Aviation
Post Office Box 3444
Denver, Colorado 80238

Dear Ms. Mayo:

This is in response to your letter of July 21, addressed to Linda Anku, Regional Administrator. You requested clarification of a number of provisions of the Occupational Safety and Health Administration's (OSHA) standard on Occupational exposure to Bloodborne Pathogens, 29 CFR 1910.1030, as applied to air ambulance operations, as well as possible recommendations we might offer relative to these operations. Your letter was referred to this office and we apologize for the delay in this response.

With regard to your first question concerning eating and drinking on extended patient transport flights, we would consider this situation to be analogous to vehicular ambulance crews who remain in the vehicle for extended periods of time. Attached is a discussion of our intent from pages 64119 and 64120 of the Summary and Explanation portion of the standard which addresses such situations. As you will note, eating and drinking is permitted in the "cab" (i.e., cockpit) of the ambulance provided that (1) the employer has implemented procedures to permit employees to wash up and change contaminated clothing prior to entering the cab; (2) consumption, handling, storage, and transport of food and drink in the rear (i.e., patient care area) of the vehicle is prohibited; and that (3) patients and contaminated material remain in the rear of the vehicle. We assume that, like vehicular ambulances, there is a separating partition between the cockpit and the patient care area of the cabin. In addition, should the cockpit become contaminated, eating and drinking in this area is prohibited until the cockpit is properly decontaminated.

Your second question regards the disposal of regulated waste. The operator (i.e., employer) of an air ambulance service is responsible for the proper handling, containerization, and labeling/color-coding of all regulated waste generated in the course of ambulance operations. It is our understanding that ground-based ambulances can often make arrangements with the various healthcare facilities they service for disposal of the regulated waste generated during transport of a patient. In those instances when the facility will not accept the waste, the ambulance service is responsible for its proper disposal. It is not OSHA's intent to set rigid regulations regarding regulated waste handling and disposal, but simply to put forth [the] minimum requirements for containing waste which the Agency has determined warrants special handling in order to protect employees against exposure to bloodborne pathogens. Additional requirements may apply to this waste under the jurisdiction of other governing bodies. Air ambulance operators should be able to obtain further information on regulations regarding disposal of regulated waste in their communities by contacting several sources including state departments or environmental protection, state health departments, local municipal governments, and waste haulers in each state.

The final portion of your letter requests information on the decontamination of plush surfaces, easy maintenance flooring/side panel materials that meet FAA regulations, and recommendations for aircraft utilizing quick-change interiors. As stated in OSHA Instruction [CPL 02-02-069 (formerly CPL 2-2.69)], "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard," a product must be registered by the Environmental Protection Agency (EPA) [or cleared by the Food and Drug Administration (FDA)] as a tuberculocidal disinfectant in order for OSHA to consider it to be effective in the cleanup or a contaminated item or surface. A solution of 5.25 percent sodium hypochlorite (household bleach) diluted between 1:10 and 1:100 with water is also acceptable for the cleanup of contaminated items or surfaces.

We can make no specific recommendations regarding flooring/side panel materials and quick-change interiors as we are not familiar with FAA regulations in this area. The standard requires the employer to maintain the worksite in a clean and sanitary condition. The employer may be able to satisfactorily accomplish the decontamination of plush surfaces. Logically however, non-absorbent firm surfaces are more easily cleaned and decontaminated. Elimination or minimization of soft plush surfaces (carpeting, velour seats/side panels, etc.) wherever possible would be beneficial from the standpoint of complying with this requirement of the standard. This would include quick-change interiors where plush surfaces are removable and able to be replaced with smooth firm surfaces.

We hope this information is responsive to your concerns and thank you for your interest in worker safety and health. Should you require further assistance, please feel to contact OSHA's regional bloodborne pathogens coordinator in our Denver Regional Office at [(303) 844-5285].

Sincerely,

Roger A. Clark, Director
[Directorate of Enforcement Programs]

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[Corrected 4/9/2004]