OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
September 13, 1990
MEMORANDUM FOR: JOHN B. MILES, JR. REGIONAL ADMINISTRATOR THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS FROM: PATRICIA K. CLARK, DIRECTOR DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS SUBJECT: Recapping Needles
This is in response to your July 17 memorandum and letter from Rosemary E. Patnode, the Northeastern Regional Industrial Hygiene Program Manager for the Department of Veterans Affairs. She inquired about the acceptability of the "one-hand scoop" method of recapping hypodermic needles.
OSHA policy is that recapping of needles, in general, is not appropriate. Used needles are to be placed in sharps disposal containers without recapping. In certain instances in which recapping is unavoidable (e.g. collection of blood for an arterial blood gas analysis), devices such as self-sheathing needles are the preferred method. Other auxiliary devices such as resheathing instruments or forceps may also be used, as may the properly performed one-hand scoop technique.
If a health care facility chooses to establish a hierarchy of preferred methods of recapping which prohibits the one-hand scoop technique, OSHA would consider that response to be an appropriate one.
Our response to Ms. Patnode's specific questions is therefore as follows:
1. Employees should not be permitted to continue routine recapping utilizing the one-hand scoop method.
2. Use of the one-hand scoop method should be limited to situations in which recapping is necessary and no preferable method is available.
July 17, 1990
MEMORANDUM FOR: Patricia Clark, Director Designate Directorate of Compliance Programs FROM: JOHN B. MILES, JR. Regional Administrator SUBJECT: Recapping Needles
Attached is a letter from Rosemary E. Patnode, the Northeastern Regional IH Program Manager for the Department of Veterans Affairs, asking about the acceptability of the "one hand scoop" method of recapping hypodermic needles. We have also enclosed two letters from this office on this subject. On the basis of conversations with Dr. Barbara Sandler/Friedman of Health Standards, we are now considering the practice to be acceptable in Region I, although to be frank we are not completely comfortable with the practice.
Since this may be a practice used nationwide at VA hospitals, we feel that it would be appropriate for an official answer to Ms. Patnode to come from your office. We will consider our policy to be an interim one until a national policy has been developed.
U.S. Department of Labor Occupational Safety and Health Administration 133 Portland Street Boston, MA 02114
Reply to the Attention of: OSHA/BOS/TS
July 9, 1990
MEMORANDUM FOR: ASSISTANT DIRECTORS ASSISTANT REGIONAL ADMINISTRATORS STATE DESIGNEES FROM: RONALD S. RATNEY Assistant Regional Administrator SUBJECT: Recapping needles
Recently Dave May, the Area Director in Concord, asked us to review a video tape of a procedure used at VA hospitals for recapping needles with one hand (the "one hand scoop method"). Our initial thought was that this could provide an opportunity for an employee to get stuck by the needle if it fell or moved so that it would become necessary to used both hands. In November 1989, we wrote a letter to the VA hospital in White River Junction, VT expressing these concerns.
More recently, I spoke with Barbara Sandler-Friedman, DDS who is working on the blood-borne disease standard in the National Office. She reported that she is telling callers that the one hand scoop technique is acceptable to OSHA along with certain other one handed recapping procedures although there is no written policy statement. In the interest of consistency, we will adopt this policy in Region I. We would be interested in hearing about one handed recapping procedures that your staffs observe and particularly, actual needle-stick experience with the practice.
U.S. Department of Labor
Occupational Safety and Health Administration
55 Pleasant Street
Concord; New Hampshire 03301
June 4, 1990
Reply to the Attention of:
TO: John B. Miles, Jr. Regional Administrator - OSHA FROM: David C. May Area Director - CAO SUBJ: Recapping Needles at VA Hospital
The attached question from the Department of Veterans Affairs in Albany, New York, is forwarded to your office for appropriate action. We have included our video which reflects the practice of some employees who feel it is safer to recap with this method than it is to reach for the sharps container, as it occurs in the facility in White River Junction, Vermont. We had conducted an ATAR inspection at this location.
Also attached are two 1989 letters addressing the same situation for your reference when developing a response to the Department of Veterans Affairs questions.
Please keep this office informed as to OSHA's answer as we will be conducting an establishment inspection at this location later this year.
P.S. Please return the video cassette after your review.
Regional Director Northeastern Region Department of Labor P.O. Box 8500 Veterans Affairs Albany, N.Y. 12208
In Reply refer to:(10BA1)
April 26, 1990
TO: John B. Miles, Jr. Regional Administrator Region 1 - OSHA THRU: David May, Area Director Concord Area Office Fed. Bldg. Rm 334, 55 Pleasant St. Concord, NH 03301