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Disinfectant policy for bloodborne pathogen cleanup

Summary A state labor official asked OSHA to clarify its bloodborne-pathogen disinfection directive. OSHA said it based the then-current disinfectant methods on CDC guidance and industrial hygiene principles for reducing worker exposure to blood or other potentially infectious materials. OSHA archives the letter and warns it may no longer represent current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-04-13
Date issued
April 13, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent current policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 13, 1994

Darrell E. Anderson, PE., CIH, CSP
Minnesota Department of Labor and Industry
[Recipient address omitted]
Dear Mr. Anderson:

This is in response to your letter of December 17, 1993, requesting clarification of the requirements for disinfection as referenced in CPL 2-2.44C, the directive for the Bloodborne Pathogens standard, 29 CFR 1910.1030. We apologize for the delay in the response. We also thank you for forwarding your decontamination/disinfection information to our staff for review.

In the CDC Morbidity and Mortality Weekly Report (MMWR) dated August 21, 1987, the CDC stated that "disinfectant-detergent formulations registered by EPA can be used for cleaning environmental surfaces, but the actual physical removal of microorganisms by scrubbing is probably at least as important as any antimicrobial effect of the cleaning agent used." The document further states "chemical germicides that are approved for use as "hospital disinfectants" and are tuberculocidal when used at recommended dilutions can be used to decontaminate spills of blood and other body fluids."

Based on this guidance, OSHA has considered the need to use a tuberculocidal germicide for the various activities which a health care worker may encounter. OSHA made the determination to require the methods of disinfection referenced in the compliance directive, CPL 2-2.44C, based on the CDC recommendations as well as industrial hygiene principles to eliminate, to the extent feasible, the source of contamination for workers who may have reasonably anticipated exposure to blood or other potentially infectious materials (OPIM). OSHA believes that the disinfectants referenced in the directive are appropriate and reasonable.

We appreciate your efforts in ensuring that the issues related to appropriate disinfection are brought to our attention.

Sincerely,
H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs

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