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Disinfectants labeled effective against HIV and hepatitis B

Summary A disinfectant maker asked whether EPA-registered products effective against HIV and hepatitis B could be used for contaminated work surfaces. OSHA initially limited their use to situations where only those two pathogens were of concern and required label-compliant concentrations and surfaces. OSHA later expanded that policy in a February 1997 memo.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-09-24
Date issued
September 24, 1996
Status
Superseded
OSHA broadened this limited-use policy in its February 28, 1997 memorandum on EPA-registered HIV/HBV disinfectants (https://www.osha.gov/laws-regs/standardinterpretations/1997-02-28-1).
Status last verified October 9, 2026

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This document has been superseded
OSHA broadened this limited-use policy in its February 28, 1997 memorandum on EPA-registered HIV/HBV disinfectants (https://www.osha.gov/laws-regs/standardinterpretations/1997-02-28-1). It no longer reflects the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

September 24, 1996
Diane Krpan
Regulatory Specialist
Buckeye International, Inc.
[Recipient address omitted]
Dear Ms. Krpan:
Thank you for your letter of August 26, concerning the Occupational Safety and Health Administration's (OSHA) policy on the use of disinfectants that are registered with the Environmental Protection Agency (EPA) as being effective against HBV and HIV.
These disinfectant products can be used under limited circumstances provided the following conditions are met. First, HBV and HIV are the only bloodborne pathogen of concern (for instance, as in a research setting), and second, the products are used in the concentrations approved by EPA. In addition, the product may be approved to disinfect only certain contaminated surfaces (such as solid versus carpet) so additional instructions on the label must be followed.
The rationale for requiring tuberculocidal agents is not based on the desire to control Mycobacterium tuberculosis, but rather to ensure the disinfectant is effective against a host of bloodborne pathogens. Therefore, when bloodborne pathogens other than HBV or HIV are of a concern OSHA continues to require the use of EPA registered tuberculocidal disinfectants.
We appreciate your support for safety and health in the workplace. If you have further questions pertaining to this matter, please contact [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

[Corrected 12/6/2024]

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