Counting contaminated laundry away from patient rooms

January 26, 1993

Mr. Stan Turbyfill
Director of Safety
National Linen Service
[Recipient address omitted]
Dear Mr. Turbyfill:

This is in response to your letter of July 7, 1992, regarding the requirements of the Occupational Safety and Health Administration (OSHA) standard, 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." I understand that some of this information has been previously communicated to you in telephone conversations with Mr. David Kendal1 of this office. You specifically requested a clarification and interpretation of paragraph 29 CFR 1910.1030(d)(4)(iv) that would permit the counting of soiled health care textiles by route sales representatives during servicing of accounts. We apologize for the delay in this written confirmation of our response.

We understand that the potential conflict you wish to avoid is with the requirement of paragraph 29 CFR 1910.1030(d)(4)(iv) that contaminated laundry be handled with a minimum of agitation and not be sorted at the location of use. You have also stated the necessity of counting items at small accounts in order to verify charges to the customer and to deliver articles in replacement.

While this provision does not prohibit you from counting the laundry near or in the vehicle or in a utility/collection area because these are not locations of use, employees performing these tasks must be provided with the full protections of the standard, including training, personal protective equipment (PPE), and hepatitis B vaccine. OSHA believes that these requirements may be adequately addressed when this sorting/counting procedure takes place in a service or utility room; however certain provisions, such as those requiring removal of PPE and handwashing, may be difficult to effectively implement when this procedure occurs at the service representative's vehicle. In order to comply with the standard, National Linen Service must assure that all provisions of the standard are adequately addressed by your procedures and that the route sales representatives follow these procedures.

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

Sincerely,
Roger A. Clark,
Director
Directorate of Compliance Programs

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