| FAQ - Sharps Safety/Postexposure Management - 2014
I recently received an email stating that OSHA now requires us to place used sharps into containers un-recapped. Is this accurate?
The OSHA Fact Sheet Protecting Yourself When Handling Contaminated Sharps states as follows:
Employers must also ensure that contaminated sharps are disposed of in sharps disposal containers immediately or as soon as feasible after use. Sharps disposal containers must be readily accessible and located as close as feasible to the area where sharps will be used. In some cases, they may be placed on carts to prevent patients, such as psychiatric patients or children, from accessing the sharps. Containers also must be available wherever sharps may be found, such as in laundries.
Contaminated sharps must never be sheared or broken. Recapping, bending, or removing needles is permissible only if there is no feasible alternative or if such actions are required for a specific medical or dental procedure. If recapping, bending, or removal is necessary, employers must ensure that workers use either a mechanical device or a one-handed technique. The cap must not be held in one hand while guiding the sharp into it or placing it over the sharp. A one-handed "scoop" technique uses the needle itself to pick up the cap, and then the cap is pushed against a hard surface to ensure a tight fit onto the device. Also, the cap may be held with tongs or forceps and placed over the needle. Contaminated broken glass must not be picked up by hand, but must be cleaned up using mechanical means, such as a brush and dust pan, tongs, or forceps. 1
In the enforcement compliance directive for the Bloodborne Pathogens Standard OSHA states:
1. Paragraph (d)(2)(vii). Shearing or breaking of contaminated sharps is completely prohibited by this paragraph. Bending, recapping, or removing contaminated needles is prohibited as a general practice. The practice of removing the needle from a used blood-drawing/phlebotomy device is rarely, if ever, required by a medical procedure. Because such devices involve the use of a double-ended needle, such removal clearly exposes employees to additional risk. Devices with needles must be used and immediately discarded after use, un-recapped, into accessible sharps containers. Certain circumstances may exist, however, in which recapping, bending, or removing needles is necessary (e.g., administering incremental doses of a medication such as an anesthetic to the same patient).
a. In these procedures, if the employer can demonstrate that such action is required by a specific medical procedure, or that no alternative is feasible, recapping must be performed by some method other than the traditional two-handed procedure, e.g., by means of a mechanical device or forceps.
b. The use of the properly performed one-hand scoop method (in which the hand holding the sharp is used to scoop up the cap from a flat surface) for recapping is a recognized and acceptable method; however, the scoop method must be performed in a safe manner and must also be limited to situations in which recapping is necessary.
c. If the employer claims that no alternative to bending, recapping, or removing contaminated needles is feasible or that such action is required by a specific medical procedure, the compliance officer should review the exposure control plan for a written justification supported by reliable evidence. This justification must state the basis for the employer's determination that no alternative is feasible or must specify that a particular medical procedure requires, for example, the bending of the needle and the use of forceps to accomplish this. 2
In summary, OSHA's Bloodborne Pathogens Standard prohibits the bending, recapping or removal of a contaminated needle or other contaminated sharp [29 CFR 1910.1030(d)(2)(vii)(A)]. The standard also provides an exception where an "employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure. Such bending, recapping or needle removal must be accomplished through the use of a mechanical device or a one-handed technique."
Please note that there may be varying requirements in those states with State OSHA Programs. It is recommended that you contact OSHA in your state to find out if there are any different requirements for the Bloodborne Pathogens Standard. Further information about State OSHA Programs can be accessed at: http://www.osha.gov/dcsp/osp/faq.html 3
1) US Department of Labor – Occupational Safety & Health Administration. OSHA Fact Sheet - Protecting Yourself When Handling Contaminated Sharps. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact02.pdf Accessed on May 14, 2014.
2) US Department of Labor – Occupational Safety & Health Administration. Directive Number: CPL 02-02-069 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2570 Accessed on May 14, 2014.
3) US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. http://www.osha.gov/dcsp/osp/faq.html Accessed on May 14, 2014.