May 18, 1992

Ms. Rebecca L. Burke
White, Verville, Fulton & Saner
Attorneys At Law
Suite 1100
1156 Fifteenth Street, N.W.
Washington, D.C. 20005

Dear Ms. Burke:

This is in further response to your letter of March 30, in which you requested clarification concerning the use of gloves in allergy testing and treatment procedures under the Occupational Safety and Health Administration (OSHA) regulation, 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens".

As you are aware, the personal protective equipment requirements of the standard are performance oriented. That is, it is the employer's responsibility to evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective equipment in accordance with paragraph (d)(3)(i) of the standard.

At a minimum, gloves must be used where there is reasonable anticipation of employee hand contact with blood, other potentially infectious material, mucous membranes, or non-intact skin; when performing vascular access procedures; or when handling or touching contaminated surfaces or items.

In general, OSHA agrees with you that gloves are not necessary when giving allergy immunotherapy injections or when performing allergy skin testing as long as hand contact with blood or other potentially infectious material is not anticipated.

You state in your letter that, following the immunotherapy injections, "there may be a drop of blood which is dabbed with cotton and a band-aid placed over it." If bleeding is anticipated and the employee is required to clean the site following injection, then gloves must be worn when doing so. As an alternative, the patient can be instructed to put pressure on the injection site with an alcohol wipe or cotton ball which the patient would then discard. Such a procedure prevents employee hand contact with blood.

Lastly, as you state in your letter, if the patient's skin is abraded, gloves would be required.

We hope this information is responsive to your concerns. Thank you for your interest in worker safety and health.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs