March 31, 2003

Ms. Janice Zalen
Director of Special Programs
American Health Care Association
1201 L St., NW
Washington, DC 20005

Dear Ms. Zalen:

Thank you for your January 3, 2003 inquiry to the Occupational Safety and Health Administration (OSHA) regarding OSHA requirements for handwashing under the bloodborne pathogens standard [29 CFR 1910.1030]. Your question has been outlined below followed by OSHA's response.

The new Centers for Disease Control and Prevention (CDC) "Guideline for Hand Hygiene in Health-Care Settings" (Morbidity and Mortality Weekly Report, October25, 2002) supports the use of alcohol-based hand rubs as an effective means for decontaminating hands in healthcare settings. Is this consistent with the requirements for handwashing established in OSHA's bloodborne pathogens standard?

Many of CDC's hand hygiene guidelines are for infection control and patient safety, which OSHA standards do not specifically address. However, we feel that these guidelines which do address occupational exposures to blood or other potentially infectious materials (OPIM) are consistent with OSHA's bloodborne pathogens standard. In paragraph (d)(2) of OSHA's standard, the section that most appropriately addresses "handwashing" in the scenario that you describe, the following is stated:

(v) Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment. (vi) Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

OSHA interprets this to mean that when an employee is removing gloves and has had contact, meaning occupational exposure to blood or blood or other potentially infectious materials (OPIM), hands must be washed with an appropriate soap and running water. If a sink is not readily accessible (e.g., in the field) for instances where there has been occupational exposure, hands may be decontaminated with a hand cleanser or towelette, but must be washed with soap and running water as soon as feasible. If there has been no occupational exposure to blood or OPIM, antiseptic hand cleansers may be used as an appropriate "handwashing" practice.

Again, if there has been no occupational exposure to or contact with blood or OPIM (as defined in [29 CFR 1910.1030(b)]), the use of alcohol-based hand cleansers described in the CDC's October 2002 guidelines would be appropriate. The application of the standard and its specific elements must be put into place where there has been actual or reasonably anticipated exposure to blood or OPIM and does not apply if no occupational exposure exists.

OSHA has consistently relied on the findings and recommendations of the CDC in developing good work practices for those employees with occupational exposure to blood or OPIM and feels that the existing standard does not compromise or contradict the recommendations included in the CDC's most recent guidelines.

Thank you for your interest in occupational safety and health. We hope that this letter clarifies your concerns. 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 createadditional 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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs