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.

November 2, 1995

David C. Yoburn, M.D.
Hypertension and Nephrology, Inc.
North Main Medical Building
1076 North Main Street
Providence, Rhode Island 02904

Dear Doctor Yoburn:

This is in response to your letter of August 7, addressed to the Occupational Safety and Health Administration (OSHA). The letter requested a clarification on OSHA's policy regarding the requirements for hand washing facilities inside an examination room per 29 CFR 1910.1030(d). The examination room in question was to be restricted for medical procedures which do not have the possibility for health care provider contact with any bodily fluids including those containing bloodborne pathogens.

The answer to your question is that if the room is truly restricted to medical procedures which do not have the possibility of bodily fluid contact, then there is no requirement to have hand washing facilities inside the room.

Your interest in occupational safety and health is appreciated. If we can be of further assistance please to contact Lewis Ligon of OSHA's Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,



John B. Miles Jr., Director
Directorate of Compliance Programs




August 7, 1995

Office of Health Compliance Assistance
USDOL-OSHA
Third and Constitution Avenue, N.W.
Washington, DC 20210

RE: Regulation Interpretation

To Whom It May Concern:

I am a physician in Providence, Rhode Island, with an office in that locale. I would like to use an examining room which does not have water facilities for simple blood pressure check in which there will be no possibility of blood-borne pathogens nor bodily fluid contamination. After contacting the local office of OSHA, it is unclear that there is a specific regulation governing this. I have contacted your office nationally and locally again and have been recommended to write to you asking for a written interpretation of the statutes that will allow us to perform our blood pressure checks and limited exams in a room without running water. I would very much appreciate if you could generate such a response for me so that I may keep it for my records. It has been the interpretation verbally of the local OSHA officers that this would be okay.

Sincerely,



David C. Yoburn, M.D., F.A.C.P.
Clinical Assistant Professor of Medicine
Brown University