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October 26, 1992

John Hall,
President
Hall Medical Laboratories, Inc.
5751 Richards Circle
Shawnee, Kansas 66216

Dear Mr. Hall:

This is in response to your letter of July 7, requesting an amendment to the Occupational Safety and Health Administration (OSHA) regulation on Occupational Exposure to Bloodborne Pathogens, 29 CFR 1910.1030 and a change in the OSHA Instruction CPL 2-2.44C, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard, 29 CFR 1910.1030." We apologize for the delay in this response.

Specifically, you requested that OSHA allow direct disposal of self-sheathing needles into regular municipal waste. You also requested that OSHA revise the language in the compliance directive which informs compliance officers that the needle sheath is not to be considered a waste container and that self-sheathing needles must be disposed of in sharps containers which are closable, puncture resistant, leakproof on the sides and bottom, and appropriately labeled or color coded.

While the State of Kansas prescribes the ultimate disposal method (e.g., landfilling, incinerating), OSHA's jurisdiction extends to the protection of employees at the worksite. Upon further review, OSHA concludes that this disposal requirement is appropriate to protect employees from potential needlesticks. We are therefore not amending this section of the compliance directive at this time.

We hope this information is responsive to your concerns. Thank you for your interest in worker safety and health.

Sincerely,



Roger. A. Clark,
Director
Directorate of Compliance Programs