Under OSHA regulations, the biohazards that your decontamination process and agents must be effective against are determined by the risks you have in your office. For example, if your office treats patients with HIV and HBV, your disinfection process and disinfectants need to be effective against HIV and HBV. In general, you also want to make sure you cover any common biohazards – household bacteria and viruses for example (OSHA deems a bleach solution as effective). Once you’ve identified what agents you must eliminate, you move on to the next step - identifying appropriate disinfectants.

Regulatory references:

1. 1910.1030(d)(4)(ii)(A) – Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.

2. Severe surface decontamination can be done using bleach (see this OSHA Decontamination Fact Sheet)

How to Identify Disinfection Products:

OSHA requires that you use “appropriate” disinfectants. In a letter of interpretation (considered legal guidance by OSHA), they defined “appropriate” as disinfectants that are EPA-registered and are labeled as effective against the hazard in question when used according to the manufacturer's guidelines. You can determine this from the manufacturer label, or by contacting the manufacturer.

Here is an excerpt from that letter of interpretation:

A review of the initial intent of the Bloodborne Pathogens Standard that specifically deals with the cleaning of contaminated work surfaces, i.e., 1910.1030(d)(4)(ii)(A), reveals that OSHA intended to provide a performance-based provision that would allow for future development of "appropriate disinfectant" products. OSHA has reviewed the information on the disinfectants and has reconsidered its position on EPA-registered disinfectants that are labeled as effective against HBV and HIV. OSHA's current stance is that EPA-registered disinfectants for HIV and HBV meet the requirement in the standard and are "appropriate" disinfectants to clean contaminated surfaces, provided such surfaces have not become contaminated with agent(s) or volumes of or concentrations of agent(s) for which higher level disinfection is recommended.

It is important to emphasize the EPA-approved label section titled "SPECIAL INSTRUCTIONS FOR CLEANING AND DECONTAMINATION AGAINST HIV-1 AND HBV Of SURFACES\OBJECTS SOILED WITH BLOOD\BODY FLUIDS." On the labels that OSHA has seen, these instructions require:

1. personal protection devices for the worker performing the task;

2. that all the blood must be cleaned thoroughly before applying the disinfectant;

3. that the disposal of the infectious waste is in accordance with federal, state, or local regulations;

4. that the surface is left wet with the disinfectant for 30 seconds for HIV-1 and 10 minutes for HBV.

OSHA would expect all such disinfectants to be used in accordance with their EPA-approved label instructions.

Additionally, the choice of disinfectants for your facility depends on factors such as low allergenicity for both patients and employees, short contact time, compatibility with surfaces in your facility, ease of use, etc.

According to CDC, potency against Mycobacterium tuberculosis has been recognized as a substantial benchmark. However, the tuberculocidal claim is used only as a benchmark to measure germicidal potency. Tuberculosis is not transmitted via environmental surfaces but rather by the airborne route. Accordingly, use of such products on environmental surfaces plays no role in preventing the spread of tuberculosis. However, because mycobacteria have among the highest intrinsic levels of resistance among the vegetative bacteria, viruses, and fungi, any germicide with a tuberculocidal claim on the label is considered capable of inactivating a broad spectrum of pathogens, including such less-resistant organisms as bloodborne pathogens (e.g., HBV, HCV, and HIV). It is this broad-spectrum capability, rather than the product's specific potency against mycobacteria, that is the basis for protocols and regulations dictating use of tuberculocidal chemicals for surface disinfection.

Required OSHA Policies and Documentation:

OSHA requires that you have a “Housekeeping” policy that explains what disinfectants you use, tasks and procedures to be performed, and locations to be cleaned. The OSHA Housekeeping Hospital eTool (applicable even for dental healthcare providers) is an excellent resource that will help you develop your procedure. 

If you’re looking for an easily customizable and ready-made protocol for Housekeeping and other required OSHA policies, check out our OSHA packages.

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