November 4, 1992

MEMORANDUM FOR:     MICHAEL G. CONNORS
                   REGIONAL ADMINISTRATOR

FROM:               ROGER A. CLARK, Director Directorate of Compliance
Programs

SUBJECT:            Application of 29 CFR 1910.1030 to Allergists

This is in response to your memo of August 28 and to confirm information verbally conveyed to Mr. William Wierdt of your staff. You requested an interpretation of the applicability of the bloodborne pathogens standard to allergists and to the practice of removing needles by hand. We apologize for the delay in this response.

While a particular allergist may not experience exposure incidents, as stated in Peggy Zwever's memo to you, procedures performed in their profession do include the reasonable anticipation of contact with blood or other potentially infectious materials. This constitutes the definition of "occupational exposure" and OSHA therefore believes that the standard is applicable to allergists who perform allergen test procedures.

Furthermore, the needles which are used to inject extracts of various allergens either subcutaneously or intradermally are considered to be "contaminated", as defined by the standard. There appears to be some confusion in the correspondence addressed to Ms. Zweber concerning the issue of contamination. While the extracts which are injected under the skin are not considered to be contaminated, the needle itself, which actually penetrates the skin, would be reasonably anticipated to involve the presence of blood or other potentially infectious material. The presence of non-visible body fluids would also constitute "contamination." Therefore these needles may not be removed by hand. They may be removed if required by a specific medical procedure or if no alternative is feasible but, in such cases, mechanical recapping and removal devices or a properly performed one-handed technique must be employed.