Spirometry tubing and bloodborne pathogen exposure

February 16, 1993

Mr. Barry J. Preston
Product Manager
Schiller America
[Recipient address omitted]
Dear Mr. Preston:

This is in response to your letter of August 31, 1992, requesting clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens". We apologize for the delay in this response.

Specifically, you inquired about the sterilization of spirometry tubing between patients and whether your sterilization procedures were adequate. You, however, are operating under an incorrect belief that "saliva is considered as a potentially infectious material in the bloodborne pathogens law". The definition of "other potentially infectious materials" includes saliva in dental procedures as well as any body fluid that is visibly contaminated with blood. Saliva that is not the product of a dental procedure or which is not visibly contaminated with blood (or for which it would not be reasonable to anticipate that it could be contaminated with blood) would not be considered to be a potentially infectious material and would, therefore, not be covered under 29 CFR 1910.1030.

In general, OSHA does not believe that spirometry tubing presents a bloodborne pathogens hazard to employees. The recommendations of the Joint Council of Allergy and Immunology that the tubing be sterilized between patients is sound public health policy but does not fall within OSHA's jurisdictional mandate to protect the health and safety of employees. If employees were to handle tubing which was contaminated with blood or other potentially infectious materials, decontamination by means of bleach or an EPA-registered disinfectant would be necessary.

We hope this information is responsive to your concerns and 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.]