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Standard Interpretations
05/25/1990 - Orthodontics wires considered as "sharps" under CPL 2-2.69 |
Standard Interpretations - Table of Contents |
| • Standard Number: | 1910.141 |
May 25, 1990 Ms. Carole Frings Federal Agency Representative American Dental Association Suite 1200 1111 14th Street, N.W. Washington, D.C. 20005 Dear Ms. Frings: This is in further response to your letter of March 20, addressed to Deputy Assistant Secretary, Alan McMillan. You requested a clarification from the Occupational Safety and Health Administration (OSHA) as to whether orthodontic wires are considered "sharps" under OSHA Instruction [CPL 2-2.69 ("Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens")] and 29 CFR 1910.141, OSHA's sanitation standard. Although neither OSHA nor the Centers for Disease Control (CDC) defines saliva as an infectious body fluid, the CDC has determined that "during dental procedures contamination of saliva with blood is predictable" (MMWR June 24, 1988, 37:377-382, 387-388) and therefore saliva in dental settings should be considered potentially infectious. OSHA's concern in this matter (as opposed to the Environmental Protection Agency) is to protect employees from puncture wounds which would expose them parenterally to potentially infectious body fluids. The ends of orthodontic wires can penetrate the skin. Since their contamination with blood can reasonably be anticipated, OSHA believes that they must be classified as "sharps" under the above referenced Instruction and standard and disposed of accordingly. In your letter you referred specifically to an inspection which occurred in Michigan. As you are aware, the State of Michigan administers its own occupational safety and health program under a plan approved and monitored by Federal OSHA. As a condition of plan approval, States must assure that they will adopt, interpret, and enforce occupational safety and health standards that are either identical to or "at least as effective" as Federal standards or requirements. Because Dr. Ponitz and other employers in Michigan must comply with the requirements of the State, he may wish to contact the Michigan Department of Public Health at the following address for more information on the State's requirements: Ms. Raj M. Wiener DirectorWe hope this information is helpful to you. Sincerely, Gerard F. Scannell Assistant Secretary [Corrected 10/29/02] March 20, 1990 Mr. Alan Mc Millan Deputy Assistant Secretary of Labor for Occupational Safety and Health Department of Labor 200 Constitution Avenue, N.W. Room S2315 Washington, D.C. 20210 Re: Clarification of Definition of "Sharps" Under OSHA Instruction 2-2.44A Dear Mr. Mc Millan: As you may recall, I was in attendance at the meeting the Association had in October with Assistant Secretary Scannell and other OSHA representatives. The purpose of this letter is to seek a clarification from OSHA as to whether orthodontic wires are considered "sharps" under the referenced Instruction and 29 CFR 1910.141. This matter was brought to our attention when a Michigan dentist named Paul Ponitz was cited for failing to treat used orthodontic wires as sharps. Copies of the citations against him are enclosed. This was the first time anyone in the Association had ever heard of OSHA interpreting orthodontic wires to be a sharp which must be disposed of in appropriate sharps containers. We are concerned because this directly contradicts the position taken by the Environmental Protection Agency (EPA), which has concluded that orthodontic wires are not sharps under the Federal Medical Waste Tracking Act and the accompanying EPA regulations. It creates major problems for our members and others when the two federal agencies regulating infectious waste interpret the waste disposal rules in an inconsistent manner. Please provide us with a written response explaining OSHA's position on this issue. Because we are in the process of doing an update on our Federal Regulatory Compliance Manual, we would appreciate a response by April 5 if at all possible. Sincerely, Carole Frings Federal Agency Representative March 22, 1990 Mr. Alan Mc Millan Deputy Assistant Secretary of Labor for Occupational Safety and Health Department of Labor 200 Constitution Avenue, N.W. Room S2315 Washington, D.C. 20210 Re: Request for Clarification of OSHA Regulations Applicable to Dentistry Dear Mr. Mc Millan: The purpose of this letter is to seek clarification of a number of OSHA regulations that may apply to dentistry. Many of these have only recently been brought to our attention and we are uncertain whether they are state-approved plan rules or federal rules, or whether they even apply to dental workers. In some cases, dentists have reported being cited by OSHA for these offenses. In other instances, dentists have simply raised the question with us in order to seek clarification of their responsibilities. Please provide us with written responses to the following questions:
Sincerely, Carole Frings Federal Agency Representative |
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