April 30, 1993

Mr. Ken Peebles
Chemical Safety & Compliance, Inc.
Suite 101
26645 W. 12 Mile Road
Southfield, Missouri 48034

Dear Mr. Peebles:

This is a final response to your letter of October 15, 1992, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." We apologize for the delay in this response.

Your specific concern was that members of the dental healthcare workforce are now being exposed to more disinfectants than ever before, as a result of decontamination requirements of the bloodborne pathogens standard. You felt that these increased chemical exposures and resulting respiratory illnesses and associated health problems that we may see in 5 or 10 years may outweigh the benefits of the decreased risk of human immunodeficiency virus (HIV) or hepatitis B virus (HBV) transmission.

The bloodborne pathogens standard is designed to protect the nation's workers, particularly health care workers, from exposure to HBV, HIV, and other bloodborne pathogens. Of the diseases caused by these viruses, hepatitis B is the most common, with 8700 cases per year among workers in the health care profession. Hepatitis B infection may result in serious illness, potential long term disability and death. HIV causes AIDS, for which there currently is no cure and which eventually results in death. These viruses, as well as other organisms that cause bloodborne diseases, are found in human blood and certain other human body fluids. Therefore, employers have a particular responsibility to ensure that workers do not come into direct contact with blood or other potentially infectious materials while performing their job. Part of this responsibility includes proper disinfection of contaminated items.

The U.S. Environmental Protection Agency (EPA) is the governmental agency which is responsible for overseeing the registration of sterilants, tuberculocidal disinfectants, and anti-microbial products. Under the bloodborne pathogens standard, OSHA requires that contaminated items and surfaces be decontaminated with an appropriate disinfectant. EPA-registered tuberculocidal disinfectants and solutions of 5.25 sodium hypochlorite (household bleach) diluted between 1:10 and 1:100 with water are considered appropriate for this purpose.

As required by the 29 CFR 1910.1200, "Hazard Communication Standard," manufacturers and distributors of hazardous materials, including tuberculocidal disinfectants and bleach, are to send a material safety data sheet (MSDS) to the purchaser of the product. In turn, the employer who receives the MSDSs is responsible for communicating the hazard information therein to the employees who will be using the product(s). In this way, employees can take the appropriate measures necessary to prevent health problems related to use of the disinfectants.

We hope this information has been responsive to your concerns. Thank you for your interest in employee safety and health.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs




October 30, 1992

Mr. Ken Peebles
Chemical Safety & Compliance, Inc.
Suite 101
26645 W. 12 Mile Road
Southfield, Michigan 48034

Dear Mr. Peebles:

This is an interim response to your inquiry of October 15, to the Occupational Safety and Health Administration's (OSHA), concerning the "Occupational Exposure to Bloodborne Pathogens Standard."

In order to address your concerns fully we are in the process of developing a detailed response. We will be providing you with a written reply shortly. Thank you for your patience.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs




October 15, 1992

Mr. Gerald Scannell
Director
Occupational Safety and Health
Administration
Department of Labor
200 Constitution Avenue, N.W.
Washington, D.C. 20210

Dear Mr. Scannell,

I have worked with over one hundred dentists this past year, assisting them in bringing their practices into compliance with the OSHA/MIOSHA regulations.

From this experience, it is my opinion that more harm is going to be done to our dental healthcare workforce from the chemical exposures they are now being exposed to rather than any perceived harm from HIV or even the well documented risk of occupational exposure to HBV.

Now that we have declared chemical warfare on HIV and HBV, and are hosing down our operatories and dental suites with all these "super", "improved" and "concentrated" disinfectants, what will our government's and OSHA's position be in 5 or 10 years when the respiratory illnesses and associated impaired health from these chemical exposures is reported in some look back study?

Respectfully submitted,



Ken Peebles