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U.S. Department of Labor | |
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| Occupational Safety & Health Administration | ||||||
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Standard Interpretations
08/12/1994 - Label Tagging Devices. |
Standard Interpretations - Table of Contents |
| • Standard Number: | 1910.1030(a); 1910.1030(c)(2) |
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August 12, 1994
This is in response to your memo of January 24, requesting an interpretation of the applicability of the bloodborne pathogens standard to employees in the garment industry and to the frequent needlestick-like occurrences when using tag attachment guns. We apologize for the delay in this response. The bloodborne pathogens standard addresses the broad issue of occupational exposure to blood and other potentially infectious materials and is not meant solely for employees in health care settings. Since there is no population that is risk free for human immunodeficiency virus or hepatitis B virus infectivity, any employee who has occupational exposure to blood or other potentially infectious material is included within the scope of this standard. While employees in the garment industry may not be generally considered to have occupational exposure, it is the employer's responsibility to determined which job classifications of specific tasks and procedures involve occupational exposure. The definition of occupational exposure means "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties". The situation which is brought to OSHA's attention involves certain employees in the garment industry who use tag attachment guns (a device which puts the price tags onto garments); there are numerous manufacturers of these devices. The procedure used with these guns is common in the industry and occurs across the country, and employees are being stuck on a regular basis; it appears to be a recognized hazard in the industry. In other words, not only is there a potential for the employees to be stuck, there is actual exposure on an anticipated level. The issue of concern relating the bloodborne pathogen standard is that these needle guns can retain blood in the hollow needle and on the tool. The needle itself, which actually penetrates the skin, would be reasonably anticipated to involve the presence of blood or other potentially infectious material. When guns are exchanged between employees, e.g., during shift changes, the result is a potential transmission of bloodborne pathogens. |
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Standard Interpretations - Table of Contents |
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