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.

February 21, 1995

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS

ATTENTION:      BLOODBORNE COORDINATORS

FROM:           JOHN B. MILES, JR., DIRECTOR DIRECTOR OF COMPLIANCE
               PROGRAMS

SUBJECT:        Reusable Sharps Containers

The purpose of this memorandum is to provide a reminder to the field concerning OSHA's policy on the proper handling of reusable sharps containers. Reusable sharps containers are an acceptable alternative to disposable containers and are permitted if the risk to servicing employees is eliminated.

The Occupational Exposure to Bloodborne Pathogens Standard contains a provision under the housekeeping requirements in paragraph (d)(4) that states in part that reusable containers shall not be opened, emptied, or cleaned manually. Compliance with this provision can be accomplished if the reusable containers are designed to be opened, emptied and cleaned using a fully automated system, and if such procedures are actually accomplished with that automated system in a manner which does not expose employees to the risk of percutaneous injury.

During inspections conducted in facilities where reusable sharps containers are handled, CSHOs are reminded to ensure that the facility is in compliance with the Bloodborne Pathogens standard as well as other applicable standards such as the Lockout-Tagout standard.

Should you have any questions concerning this matter, please contact Wanda Bissell of the Office of Health Compliance Assistance at (202) 219-8036.