Are Employers Obligated to Disinfect Shared Office Keyboards?

OSHA's recordkeeping regulation requires employers to record work-related illnesses (such as SARS or MRSA) on the OSHA 300 log, but does this requirement apply to recording illnesses that are spread through workplace contacts with contaminated surfaces, such as on shared keyboards? That is what one doctor at a medical facility in Maryland wanted to know, so he wrote a letter asking the agency about it. The response: It depends.

In an official Letter of Interpretation dated June 22, 2009, and posted to OSHA’s Web site this week, Richard E. Fairfax, director of the agency’s Enforcement Programs Directorate, explained the criteria for an illness to be recordable, saying, “[A]n employee must be infected as a result of a workplace exposure, and one of the following must also be true: a) medical treatment is provided; or b) the employee misses at least one full day of work. In addition, an injury or illness is recordable if it meets one or more of the criteria outlined in 29 CFR 1904.7 through 1904.11.”

As to whether employers are obligated to disinfect items such as shared workplace keyboards whose use could potentially spread disease, Fairfax said OSHA’s determination of coverage under Section 5(a)(1) of the OSH Act “would be made on a case-by-case basis.”

The director noted that in a health care facility, where workers can routinely be exposed to all manner of infectious diseases transmitted through contact with contaminated surfaces, it is important for the facility to institute measures that will minimize or eliminate the risk. “One way to reduce the potential for transmitting infectious diseases is to institute measures to prevent surfaces/fomites from becoming contaminated in the first place,” Fairfax wrote. “Washing hands with soap and water following contact with patients is a major way of minimizing the potential for fomite contamination.”

He did not address the obligations of employers in non-health care settings.

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