Disinfectants labeled effective against hepatitis B and HIV

April 1, 1997
Mr. Thomas H. Bach
Technical Services Manager
Reckitt & Colman Inc.
[Recipient address omitted]
Dear Mr. Bach:
This is in response to your letter of December 10, 1996. You have requested a clarification of the Occupational Safety and Health Administrations (OSHA) position on disinfectants claiming efficacy against the Hepatitis B virus. You have asked if the products with the EPA approval meet the requirements of the Bloodborne Pathogens Standard without a registered tuberculocidal claim.
A review of the initial intent of the Bloodborne Pathogens Standard that specifically deals with the cleaning of contaminated work surfaces, i.e., 1910.1030(d)(4)(ii)(A), reveals that OSHA intended to provide a performance-based provision that would allow for future development of "appropriate disinfectant" products. OSHA has reviewed the information on the disinfectants and has reconsidered its position on EPA-registered disinfectants that are labeled as effective against HBV and HIV. OSHA's current stance is that EPA-registered disinfectants for HIV and HBV meet the requirement in the standard and are "appropriate" disinfectants to clean contaminated surfaces, provided such surfaces have not become contaminated with agent(s) or volumes of or concentrations of agent(s) for which higher level disinfection is recommended.
It is important to emphasize the EPA-approved label section titled "SPECIAL INSTRUCTIONS FOR CLEANING AND DECONTAMINATION AGAINST HIV-1 AND HBV Of SURFACES\OBJECTS SOILED WITH BLOOD\BODY FLUIDS." On the labels that OSHA has seen, these instructions require:

1. personal protection devices for the worker performing the task;
2. that all the blood must be cleaned thoroughly before applying the disinfectant;
3. that the disposal of the infectious waste is in accordance with federal, state, or local regulations;
4. that the surface is left wet with the disinfectant for 30 seconds for HIV-1 and 10 minutes for HBV.

OSHA would expect all such disinfectants to be used in accordance with their EPA-approved label instructions.
We thank you for your interest in workplace safety and health. Should you have further questions, please call [the Office of Health Enforcement at 202 693-2190].
Sincerely,
John B. Miles, Jr., Director
[Directorate of Enforcement Programs]
[Corrected 2/10/2005]

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