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OSHA Standards
Interpretation and Compliance
Letters
10/22/1992 -
Applicability of bloodborne pathogens standard to first aid providers at
drilling operations.
OSHA Standard
Interpretation and Compliance Letters - Table of Contents
Record
Type: Interpretation
Standard
Number: 1910.1030
Subject:
Applicability of bloodborne pathogens standard to first aid
providers at drilling operations.
Information Date: 10/22/1992
October 22,
1992
Mr. Larry G.
Richardson
Director of
Safety and Training
Noble Drilling
Services, Inc.
Suite 400
10370 Richmond
Avenue
Houston, Texas
77042
Dear Mr.
Richardson:
This is in
response to your letter of August 31, regarding the applicability of
29 CFR 1910.1030, "Occupational Exposure to Bloodborne
Pathogens", to drilling operations. 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 and hepatitis B virus infectivity, any
employee who has occupational exposure to blood or other
potentially infectious materials is included within the scope of
this standard.
It is important
to note that the definition of "occupational exposure" comprises the
reasonable anticipation that the employee will come into
contact with these fluids during the course of performing his or her
work duties. Therefore, OSHA anticipates that this
standard will impact upon all non-health care industries in a
similar fashion, i.e., that employees who are designated as responsible
for rendering first aid or medical assistance as part of their job
duties are to be covered by this standard. This is because it
is reasonable to anticipate that an employee designated to render
first aid will have occupational exposure to blood or other
potentially infectious materials.
Employees who
perform "Good Samaritan" acts are not, per se, covered by this
standard, although OSHA would encourage an employer to
offer follow-up procedures to an employee who experiences an
exposure incident as the result of performing a "Good
Samaritan" act. This is because such an action does not constitute
"occupational exposure", as defined by the standard. The
key to this issue is not whether employees have been trained in
first aid, but whether they are also designated as responsible
for rendering medical assistance. While many workers may be trained
in first aid and CPR, not all of these employees would
necessarily be designated to render first aid.
Please note
that OSHA has recently issued a policy statement specifying that
failure to offer the hepatitis B vaccine pre-exposure to
persons who render first aid only as a collateral duty, will be
considered a technical violation carrying no penalties,
provided that a number of conditions are met. These conditions are
described in the enclosed news release.
We hope this
information is responsive to your concerns. Thank you for your
interest in employee safety and health.
Sincerely,
Roger A. Clark,
Director
Directorate of
Compliance Programs
August 31, 1992
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