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.

November 9, 1992

Mr. Vincent W. Foglia
Sage Products Inc.
815 Tek Drive Crystal
Lake, Illinois 60014

Dear Mr. Foglia:

It has recently come to our attention that your SAGE sharps container (model #8965-1) was involved in a needlestick injury in a hospital in the State of Vermont. The Occupational Safety and Health Administration (OSHA) would appreciate you providing us with information about this product.

Since the main function of OSHA is to prevent employee injuries and illnesses, the Directorate of Technical Support is considering issuing a Hazard Information Bulletin (HIB) on this particular device. HIBs are prepared based on information provided to us by our field staff, concerns expressed by safety and health professionals, employers, and the public.

Before issuing a HIB, we solicit your cooperation in providing us with relevant information. For instance, what is the Food and Drug Administration approval number of this device, if applicable? Is this device still being sold and, if so, have any design modifications been made to this product to prevent needlestick injuries? Has your company issued an alert to the distributors or users of this device warning of potential problems? Have operating instructions been modified or amended? In addition we would appreciate receiving any other information you deem relevant to the safe use of your sharps container.

Your cooperation will further the overall objective of the Occupational Safety and Health Act, to assure so far as possible safe and healthful working conditions for all American workers. We would appreciate your response by November 30.

If we can be of assistance to you in any way, please call Ira Wainless of my staff at (202) 219-7056.

Your cooperation is greatly appreciated.


Patricia K. Clark
Directorate of Technical Support