Bloodborne-pathogen duties in dry-cleaning shops

February 27, 1996

Ms. Mary Scalco
International Fabricare Institute
[Recipient address omitted]
Dear Ms. Scalco:

This letter is in response to the letter addressed to this Directorate from Mr. John Meijer last June. We appreciate your taking the time and coming in to talk to us about your concerns on October 12. The essential points addressed by your letter involve the situations under which dry cleaning establishments would be covered by the bloodborne pathogens standard. Following your discussion with my staff on the issue of coverage we have come to the following conclusions:

1. If a dry cleaning establishment maintains contracts with establishments such as health care facilities, fire departments, and/or police departments where one could reasonably anticipate that clothing cleaned under these contracts could be contaminated by blood or other potentially infectious materials (OPIM), OSHA would expect that those employers are fully covered by the standard (29 CFR 1910.1030). Once the material had been cleaned it would no longer be regarded as potentially infectious.

2. In dry cleaning establishments that do not maintain the types of contracts described in No. 1, OSHA would not enforce the standard, but would require the training of workers (especially those that receive the clothing articles) to recognize potentially contaminated clothing. Once clothing has been recognized as such, each separate facility would need to make a determination as to whether or not it will clean such clothing. If the facility elects not to handle the clothing, then procedures should be in place to refer the customer elsewhere. In addition to this limited training, OSHA would expect the post exposure follow-up portion of the standard to be implemented if an actual exposure incident were to occur. The requirements under a post-exposure evaluation and follow-up are covered under section 29 CFR 1910.1030(f)(3) of the standard. The hepatitis vaccination would not be required of workers in this category unless recommended by the examing physician under the post exposure evaluation procedures.

If the facility elected to clean material that has been recognized as potentially contaminated, the facility should set the clothing aside and handle it separately. Individuals in the facility that would handle, launder, or dry clean such potentially contaminated materials would need to be thoroughly trained under the requirements of the bloodborne pathogens standard. Training shall also include the use of proper personal protective equipment, such as gloves and aprons, and the work practices that must be implemented to avoid exposure. The vaccination series for hepatitis B would not be required until there was an actual exposure incident (where there was skin contact) as part of the post exposure follow-up procedures. The facility would not need to train and provide the hepatitis vaccination to all individuals in the facility, but only to those that have been so exposed.

If you have any additional questions or if we can be of any further assistance please contact Richard Fairfax of my staff at [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

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

[Corrected 12/6/2024]