Nail and tissue clippers as contaminated sharps

April 4, 1992

Susan K. Moore, D.P.M.
[Recipient address omitted]
Dear Dr. Moore:

This is in response to your letter of March 2, in which you requested clarification concerning the requirements of 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens."

This regulation states that the body substances to which universal precautions must be applied are blood and other potentially infectious materials. Toenail clippings and skin shavings are included if they are contaminated with blood or blood components, such as exudates from wounds.

Similarly, nail clippers and tissue clippers which are contaminated with blood or other potentially infectious materials would be considered sharps which must meet the handling and labeling requirements of the standard if they are capable of penetrating the skin. "Contaminated" means the presence or reasonably anticipated presence of blood or other potentially infectious material on an item or surface.

The Occupational Safety and Health Administration (OSHA) expects that these instruments would be disinfected regardless of their coverage under this regulation due to the possibility of transmission of non-bloodborne diseases.

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

Sincerely,
Dorothy L. Strunk
Acting Assistant Secretary

[Requester letter reproduced on OSHA page; omitted here.]