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  • U.S. Department of Labor
  • Occupational Safety and Health Administration
  • Directorate of Technical Support and Emergency Management
  • (formerly Directorate of Science, Technology and Medicine)
  • Office of Science and Technology Assessment

OSHA Hazard Information Bulletins
Sharps Disposal Containers with Needle Removal Features


March 12, 1993

MEMORANDUM FOR:

REGIONAL ADMINISTRATORS

THROUGH:

  • LEO CAREY
  • Director
  • Office of Field Programs

FROM:

  • PATRICIA K. CLARK
  • Director
  • Directorate of Technical Support

SUBJECT:

  • Hazard Information Bulletin1 - Sharps Disposal Containers with Needle Removal Features

The purpose of this bulletin is to alert field personnel to the possible safety and health risks that may arise with the use of some sharps disposal containers that incorporate an "unwinder" mechanism to accomplish needle removal. Unwinders are used to separate needles from syringes or phlebotomy needles from blood collection ("vacutainer") apparatus.

In general, sharps containers used for discarding contaminated needles must be closable, puncture-resistant, leakproof on the sides and bottom, and appropriately labeled or color coded (1910.1030(d)(4)(iii)(A)1). Additionally, the Occupational Exposure to Bloodborne Pathogens Standard (1910.1030) prohibits needle removal unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. Needle removal must be accomplished through the use of a mechanical device or a properly performed one-handed technique (1910.1030(d)(2)(vii)(B)). Sharps containers which have well designed unwinders may be used.

However, it has recently come to our attention that some sharps containers do not have well designed unwinders and, therefore, do not meet the intent of the engineering and work practice controls provision of the standard. The design of some of these needle unwinders can cause needle stick injuries when the container becomes overfilled, or when the unwinder fails to properly secure the needle during the removal process.

As stated in OSHA Instruction CPL 2-2.44C, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard," needle removal devices should not create additional hazards. The design of the sharps container and the location of the unwinder must allow the needle removal to be accomplished in a safe one-handed manner. In addition to the above mentioned safety characteristics, evaluation of such sharps containers should also consider the following safety features:

  1. The sharps container should be designed so that it is easily and safely determined when the container needs to be emptied; this avoids overfilling and reduces the risk of injury.
  2. The sharps container with an unwinder should be stabilized (secured to a wall, table, or tray) to prevent slipping during use.
  3. The design of the unwinder must allow the employee to use the unwinder with a one-handed technique; that is, the employee must not be required to secure the needle with one hand while it is being unwound by the other hand.
  4. The unwinder should be designed so that the needles do not slip or slide within the unwinder during the needle removal process; the unwinder should provide a secure capture that prevents movement of the needle while it is removed.

OSHA recommends that procedures requiring needle removal be carefully evaluated to determine the feasibility of equipment redesign or changes in work practices.

Please distribute this bulletin to all Area Offices, State Plan States, Consultation Projects and appropriate local labor and industry associations.

References

1 The Directorate of Technical Support issues Hazard Information Bulletins (HIBs) in accordance with OSHA Instruction CPL 2.65 to provide relevant information regarding unrecognized or misunderstood health hazards, inadequacies of materials, devices, techniques, and safety engineering controls. HIBs are initiated based on information provided by the field staff, studies, reports and concerns expressed by safety and health professionals, employers, and the public. Information is complied based on a thorough evaluation of available facts, literature and in coordination with appropriate parties.

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