Reusable and disposable tracheostomy cannulas under the bloodborne pathogen rule

April 25, 1994

Mr. Jeff Hennelly
Strategic Manager
Mallinckrodt Medical TPI, Inc.
[Recipient address omitted]
Dear Mr. Hennelly:

Thank you for your letter of March 29, 1993, in which you requested that OSHA provide an opinion concerning two different methods of inner cannula care, the disposable cannula and the reusable cannula.

OSHA does not review or endorse products as you have requested. The final determination of compliance with OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030, must take into account all factors pertaining to the use of such devices at a particular worksite. This must include an evaluation through direct observation of employee work practices as well as an evaluation of the potential exposure to blood or other potentially infectious materials (OPIM) which the use of the device will cause an employee.

As you are aware, the Bloodborne Pathogens standard attempts to minimize the employee's exposure to blood or OPIM. OSHA does not mandate that facilities use disposable devices in order to accomplish this goal. The employer should make the determination whether the reusable or the disposable device better satisfies their needs.

We are enclosing the copy of the videotape which you provided us for review. We appreciate your interest in safety and health.

Sincerely,
Ruth E. McCully, Director
Office of Health Compliance Assistance

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