14.2 OSHA, FDA, EPA, and CDC Standards

The Oregon Barbering Examination Information Bulletin (revised October 25, 2019) assigns 4 of 100 theory items to Federal Regulations and Standards: Occupational Safety and Health Administration (OSHA), Food and Drug Administration (FDA), Environmental Protection Agency (EPA), and Centers for Disease Control and Prevention (CDC). Oregon does not reprint those four agencies as Board-only license text. OAR 817-010-0007 requires authorization holders to observe the Department of Human Services, the Oregon Health Authority, and all other applicable city, county, state, and federal regulations. The exam asks you to know which agency does what, then how Chapter 817 maps those federal claims onto the jug, the autoclave, and the formaldehyde bottle.

HLO sources theory in Milady's Standard Professional Barbering, 5th Edition (2011) and Pivot Point Barbering Fundamentals, 1st Edition (2018). The laws paper then asks the Oregon names: high-level disinfectant, FDA-listed sterilizer, OR-OSHA formaldehyde. A candidate who can recite “OSHA” but credits the FDA with registering the tuberculocidal jug has the agencies backward.

Why the four agencies matter on both papers

Safe-usage habits from the previous section are how you work. This section is who sets the claim on the label. OSHA writes workplace bloodborne and chemical-hazard rules. FDA splits a cosmetic from a drug and lists devices. EPA registers disinfectants, including hospital-grade and tuberculocidal claims. CDC publishes Standard Precautions. Oregon then writes the shop translation in OAR Chapter 817. Do not memorize unpublished OSHA citation dollar amounts. Fine schedules change. The exam tests the standard, not last year’s civil-penalty table.

OSHA: Bloodborne Pathogens, Hazard Communication, Right to Know

OSHA is the federal workplace-safety agency. Barbering texts test three OSHA ideas.

First, the Bloodborne Pathogens Standard (29 CFR 1910.1030). Treat blood and other potentially infectious materials (OPIM) as infectious. Use an exposure control plan, engineering controls (a sharps container), work-practice controls (do not recap by a two-handed pocket scoop), personal protective equipment (PPE) (gloves, eye protection, mask), hepatitis B vaccination for employees with occupational exposure, and post-exposure evaluation. Oregon’s shop translation is OAR 817-010-0008 (wash, gloves, eyes or mask) plus OAR 817-010-0060 (biohazard sharps and blood waste). Renewal bloodborne pathogens (BBP) training under OAR 817-008-0000 and Senate Bill 217 is how Oregon keeps that knowledge current after you pass: attest at field-of-practice renewal on or after July 1, 2025; HLO’s FAQ (revised April 2, 2026) states certifications are valid for one year; keep records five years; produce them within 30 calendar days if audited. Do not mail the card with the renewal.

Second, the Hazard Communication Standard (HazCom, 29 CFR 1910.1200), often called Right to Know. Workers have a right to know the chemical hazards in the shop. The employer must maintain Safety Data Sheets (SDS), keep labels on containers, and train workers on the chemicals they use. Oregon’s chemical rules still say Material Safety Data Sheet (MSDS) in OAR 817-060-0030; on the theory paper, SDS is the current OSHA name. Do not use a cosmetic product containing a substance the FDA has banned for cosmetics. Do not use a product in a manner the FDA has not approved (OAR 817-060-0030).

Third, Oregon Occupational Safety and Health Division (OR-OSHA) adopts federal OSHA rules in OAR Chapter 437. For formaldehyde, OAR 817-060-0050 requires adherence to all city, county, state, or federal formaldehyde rules and adopts OAR 437-002-0360 by reference (that Board rule cites the July 2013 version). For that rule, “employer” means a facility license holder, temporary facility permit holder, demonstration permit holder working outside a licensed facility, a practitioner working outside a licensed facility, or an independent contractor. “Employee” means a practitioner working in a licensed facility, an individual working under an independent contractor or facility license holder, or a demonstration permit holder working in a licensed facility. Formaldehyde detail belongs in Chapter 21. The federal item here is: Oregon adopted OR-OSHA; it did not invent a private formaldehyde code.

FDA: cosmetics versus drugs; devices, not disinfectants

The FDA regulates cosmetics, drugs, and medical devices. It does not register the shop disinfectant. That is EPA.

A cosmetic is intended to cleanse, beautify, or promote attractiveness — shampoos, conditioners, styling aids, shaving creams, aftershaves, most barber products. A drug is intended to treat or prevent disease or to affect the structure or function of the body beyond cosmetics. An anti-dandruff shampoo that claims to treat a disease is a drug or a cosmetic-drug. Oregon barbering is cosmetic, not medical (ORS 690.005(2)). Do not sell a “scalp treatment” as a medical cure.

Clippers, trimmers, and sterilizers used on people are devices. OAR 817-010-0065 requires any product or manual, mechanical, or electrical appliance used in a field of practice to meet all product-registration requirements of any federal, state, county, city, or other regulating authority, to be used as the manufacturer intended, and to be backed by the holder’s training records. If the shop uses sterilization equipment, OAR 817-010-0068(8) is more specific: approved equipment is a steam sterilizer registered and listed with the FDA, or a dry heat sterilizer or autoclave registered and listed with the FDA, maintained and used per the manufacturer’s instructions. “Registered and listed with the FDA” is the Oregon phrase. A kitchen pressure cooker is not that equipment. An ultraviolet cabinet is not a substitute for high-level immersion of a razor.

EPA: the disinfectant agency

The EPA registers pesticides, including disinfectants, under federal pesticide law. Hospital-grade (hospital-level) disinfectant claims and tuberculocidal claims are EPA label claims, not Board inventions. Oregon’s mapping is a two-part definition in OAR 817-005-0005:

• High-level disinfectant: a chemical agent that has demonstrated tuberculocidal activity and is registered with the EPA.
• Low-level disinfectant: EPA-registered and bactericidal, germicidal, fungicidal, and limited virucidal.

EPA-registered but not tuberculocidal is not high-level. A tuberculocidal marketing line without an EPA registration is not Oregon’s high-level either. Sharps (razors, shears) require high-level immersion after clean and rinse (OAR 817-010-0068(7)). Electrical clipper blades are saturated with high-level solution, spray, or foam (OAR 817-010-0069). Combs and brushes go in 1,000 parts per million (ppm) of a commercial quaternary ammonium compound (quats) or another low-level disinfectant. Do not credit the FDA with the jug. Do not credit OSHA with registering a pesticide.

CDC: Standard Precautions, tested but not a Board license clause

The CDC publishes Standard Precautions: treat all blood, OPIM, nonintact skin, and mucous membranes as potentially infectious, whether or not the client “looks healthy.” Standard Precautions expanded older Universal Precautions. Oregon does not enforce “CDC Standard Precautions” as a named license condition the way it names EPA-registered tuberculocidal disinfectant. The bulletin still tests the CDC idea. The Board’s enforceable translation is wash before and after, glove for routine blood, eye or mask if spatter, high-level on blood surfaces, and a biohazard-labeled sharps container.

Do not credit EPA for listing an autoclave. Do not credit FDA for registering the tuberculocidal jug. Do not credit CDC with Oregon’s high-level definition. Do not invent an OSHA fine to “prove” you studied.

An Eugene autoclave and a hospital-grade jug

Priya, a certificate holder in Eugene, buys a used countertop “sterilizer” with no FDA listing and a jug labeled “hospital-grade” that is EPA-registered but not tuberculocidal. She immerses the straight razor in that jug and tells the next client the shop “autoclaves everything.” That story fails the four federal items. Sterilization equipment, if used, must be a steam or dry-heat unit registered and listed with the FDA (OAR 817-010-0068(8)). High-level for the razor is EPA-registered and tuberculocidal, not “hospital-grade” as a substitute word. OSHA still wants an SDS for the jug and a sharps container for a used changeable blade. CDC Standard Precautions would have treated the last client’s nick as infectious without a health history. Oregon will score the same facts as OAR numbers on the laws paper.