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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 10, 1994
Mrs. Molly Ruscoe Clinical Representative Bioject Inc. 7620 S.W. Bridgeport Road Portland Oregon 97224
Dear Ms Ruscoe:
This is in response to your letter of August 22, 1994 requesting a written opinion on the disposal of the needle-less Biojector Syringe.
The background information you provided, as well as the Instruction Manual has been reviewed. Occupational Safety and Health Administration's (OSHA) does not regulate the management of uncontaminated instruments or sharps. Since they are sterile they do not present a Bloodborne pathogen transmission hazard. This would certainly apply to the needle as described in your literature.
The needle-less Biojector Syringe is not a "sharp" object as you pointed out, however it may become contaminated with blood as the syringe tip contacts the injection site. It would be necessary to dispose of the contaminated syringe in accordance with OSHA's Bloodborne Pathogen standard by placing it into a leak-proof color-coded or labelled container.
We hope this information answers your concerns and questions. Thank you for your interest in worker safety and health.
Ruth E. McCully, Director Office of Health Compliance Assistance