Does the bloodborne pathogens standard apply to hepatitis C?

When OSHA published the bloodborne pathogens standard in the Federal Register on December 6, 1991, the preamble included the definition of bloodborne pathogens. The preamble defines bloodborne pathogens to include “HBV, HIV, and other pathogens including hepatitis C, malaria, syphilis, babesiosis, brucellosis, leptospirosis, arboviral infections, relapsing fever, Creutzfeld-Jakob Disease, Human T-lymphotrophic virus Type I, and viral Hemorrhagic Fever.” The preamble adds, “HBV and HIV are given as examples in the standard because they are the viruses of greatest interest and present the greatest risk.”

So, where employees face occupational exposure to hepatitis C, the employer is required to follow OSHA’s standard. However, a March 25, 1999, OSHA letter of interpretation clarifies that not all provisions of the bloodborne pathogens standard apply to hepatitis C. For example:

• 1910.1030(e) only applies to HIV and HBV research laboratories and production facilities.
• 1910.1030(f)(1)(i), (f)(2), (f)(4)(i) and (f)(5)(i) only apply to HBV (HBV vaccination, information provided to healthcare professional, and healthcare professional’s written opinion).
• 1910.1030(f)(3)(ii)(A)-(C) and (f)(3)(iii) only apply to testing for HBV and HIV after an exposure incident.
• 1910.1030(g)(1)(ii) only applies to signs in HIV and HBV research laboratories and production facilities.
• 1910.1030(g)(2)(vii)(I) only applies to training about the HBV vaccine.
• 1910.1030(g)(2)(ix) only applies to training in HIV and HBV laboratories and production facilities.
• 1910.1030(h)(1)(ii)(B) only applies to keeping records of an employee’s HBV vaccination status.