Face and eye protection for phlebotomists

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 16, 1995

MEMORANDUM FOR: MICHAEL G. CONNORS
REGIONAL ADMINISTRATOR

FROM: JOHN B. MILES, JR., DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Face and Eye Protection for Phlebotomists

This memorandum is in response to your letter dated January 23, requesting that we review bloodborne pathogens standard citations issued to the American Red Cross by the Cleveland Area Office. You asked that an interpretation be provided on whether face protection is required for phlebotomists. In OSHA's view, exposure to blood during phlebotomy is not reasonably anticipated and face and eye protection is not required.

As you know, the selection of personal protective equipment for occupational exposure to bloodborne pathogens is based on reasonably anticipated exposure. During routine phlebotomy it is not reasonably anticipated that blood will reach the eyes or mouth of the employee and eye or face protection is not required. This is particularly true in a blood donor center since the donor is a volunteer and is not typically unruly or out of control.

In this particular case, the accident reports dating from 1992 to 1994 show that only 2 of the 17 exposure incidents occurred while drawing blood. One exposure incident (which occurred on October 26, 1992) appears to have affected a third party (the Health Historian) in the near proximity and not the nurse performing the actual blood draw. If the interpretation of the incident is accurate, then that exposure incident could not have been anticipated. That leaves one recorded exposure that occurred while a phlebotomist was removing a needle from a donor for the three year time period studied. This data further supports that blood splashes to the face and eyes of phlebotomists are rare.

The remaining 15 exposure incidents recorded in that time period have been reviewed, and appear to be incidents that occurred while employees were conducting lab tasks. In these situations when laboratory technicians are conducting blood-related lab activities, there may be a reasonably anticipated exposure to blood and eye or face protection or some other control method may be required.

In summary, please bear in mind that phlebotomy involves the drawing of blood from a vein rather than from an artery which is under pressure. If the phlebotomist mistakenly tries to draw blood from an artery, then a splash of blood could occur. In this case, there may be a skill deficiency which requires training. A properly trained phlebotomist is not reasonably anticipated to experience a splash of blood to the eye and face and eye or face protection is not required.

We hope this answers your concerns. If you have any further questions please contact Wanda Bissell at (202) 219-8036.

[Earlier OSHA regional memorandum and related inspection attachments reproduced on OSHA page; omitted here.]