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Frequently Asked Questions: Bloodborne Pathogens
- Are employers responsible for providing sharps containers for
employees who are diabetic and need insulin shots in a non-health care related
facility?
- What does OSHA currently accept as “appropriate” disinfectants to
prevent the spread of HIV and HBV?
Are employers responsible for providing sharps
containers for employees who are diabetic and need insulin shots in a non-health care
related facility?
Discarded insulin syringes create a potential for exposure for persons emptying the trash
whether the insulin is administered by the diabetic himself/herself or by a health care worker
and whether the disposal occurs in a health care facility or elsewhere. The employer has the
responsibility for protecting custodial workers who are encountering discarded insulin
syringes in the trash. This can be accomplished by including those custodial workers in the
exposure control plan or by other means such as requiring insulin-using employees to discard
their used syringes in special containers.
Reference Interpretation and Compliance Letters:
What does OSHA currently accept as “appropriate”
disinfectants to prevent the spread of HIV and HBV?
A review of the initial intent of the Bloodborne Pathogens Standard that specifically deals
with the cleaning of contaminated work surfaces, i.e., 1910.1030(d)(4)(ii)(A), reveals that
OSHA intended to provide a performance-based provision that would allow for future development
of "appropriate disinfectant" products. OSHA has reviewed the information on the disinfectants
and has reconsidered its position on EPA-registered disinfectants that are labeled as
effective against HBV and HIV. OSHA's current stance is that EPA-registered disinfectants for
HIV and HBV meet the requirement in the standard and are "appropriate" disinfectants to clean
contaminated surfaces, provided such surfaces have not become contaminated with agent(s) or
volumes of or concentrations of agent(s) for which higher level disinfection is recommended.
It is important to emphasize the EPA-approved label section titled "SPECIAL INSTRUCTIONS FOR
CLEANING AND DECONTAMINATION AGAINST HIV-1 AND HBV Of SURFACES\OBJECTS SOILED WITH BLOOD\BODY
FLUIDS." On the labels that OSHA has seen, these instructions require: 1) personal protection
devices for the worker performing the task; 2) that all the blood must be cleaned thoroughly
before applying the disinfectant; 3) that the disposal of the infectious waste is in
accordance with federal, state, or local regulations; 4) that the disposal of the infectious
waste is in accordance with federal, state, or local regulations; and 5) that the surface is
left wet with the disinfectant for 30 seconds for HIV-1 and 10 minutes for HBV. OSHA would
expect all such disinfectants to be used in accordance with their EPA-approved label
instructions.
Reference Interpretation and Compliance Letters:
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