May 1, 1995

MEMORANDUM FOR:           MICHAEL G. CONNORS
                         REGIONAL ADMINISTRATOR

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

SUBJECT:                  AMERICAN RED CROSS

This memorandum is in response to your letter dated January 23, requesting that we review the American Red Cross citations issued by the Cleveland Area Office. You asked that an interpretation be provided on whether face protection is required for phlebotomists.

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 3-year time period studied. This data further demonstrates 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.