Disinfectants for blood cleanup and dental protective clothing

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 19, 1990

MEMORANDUM FOR: LINDA R. ANKU
REGIONAL ADMINISTRATOR

FROM: PATRICIA K. CLARK DIRECTOR
DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS

THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS

SUBJECT: CPL 2-2.44B Clarifications

This is in response to your May 15 memo requesting clarification of the following two issues: (1) the overall effectiveness of products registered with the EPA as effective against the human immunodeficiency virus (HIV) and (2) the length of sleeves necessary to protect dentists from exposure to blood and/or body fluids.

The attached letter and updated listings clarify the intent of the Environmental Protection Agency (EPA) in this matter. List A identifies sterilants which represent the highest level of antimicrobial activity and are intended to destroy all viruses. List B identifies disinfectants which have been documented as effective against tuberculosis bacteria and the specific viruses named on the product label. List C details products that are registered with the EPA as effective specifically against the AIDS virus. The attached February 9, 1989, Federal Register notice clarifies the EPA's labeling requirements for HIV efficacy claims.

Paragraph M.2.b. of OSHA Instruction CPL 2-2.44B describes the types of products which may be used following the initial cleanup of blood or body fluids. The intent of the disinfectant category in paragraph M.2.b.(2) is to allow the use of products registered by the EPA as being effective against HIV for cleanups in which HIV is the only infectious matter of concern (e.g., those fluids found in HIV experimental laboratories). To determine the overall effectiveness of a particular product for use in a cleanup where HBV or other bloodborne pathogens are also of concern, one must compare the listing of HIV-effective products with the other two listings to check if they overlap for the product of interest. You are correct in your assumption that a product which is only effective against HIV may very well not be effective against HBV which is much more resistant to activation than is HIV. Thus the need to compare the listings. For additional information on this subject you may wish to contact Dr. Jean Jenkins or William Campbell of EPA's Antimicrobial Program Branch at (703) 557-7443 or 557-7470, respectively.

With regards to your second inquiry, both the OSHA Instruction CPL 2-2.44B and the proposed regulation on Occupational Exposure to Bloodborne Pathogens are performance oriented and allow for the exercise of professional judgement in determining the protective equipment which is appropriate to protect the skin from blood or body fluids. The final determination regarding the existence of a hazard (in this case exposure of the forearms to blood and body fluids) must be made in the workplace by direct OSHA compliance officer observation of the particular situation.

As a point of interest, the American Dental Association's Infection Control Guidelines states that "long sleeves and high collars that protect the user from the spatter of body fluids and which cover street clothing provide the best coverage."

Attachments

[May 15 regional memorandum and EPA explanatory letter reproduced on OSHA page; omitted here.]