Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

March 13, 2000

Mr. Steve Blazejewski
Collection Systems Product Manager
Kendall Healthcare Products Company
15 Hampshire Street
Mansfield, MA 02048

Dear Mr. Blazejewski:

Thank you for your February 1 letter addressed to the Occupational Safety and Health Administration's (OSHA's) Office of Health Compliance Assistance (OHCA). You have a question regarding the disposal of plastic blood collection tubes. Your question is outlined below, followed by OSHA's response.

Our (Kendall's) question surrounds "red bagging" as pressure is applied during disposal (of plastic blood collection tubes), the potential for breakage exists, and therefore, a puncture-resistant container is necessary. How does this interpretation letter (regarding plastic syringes, Sept. 25, 1997) compare to plastic blood collection tubes?

According to the Bloodborne Pathogens Standard, 29 CFR 1910.1030, paragraph (b), used blood collection tubes meet the definition of regulated waste; "a liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials." As such, regulated waste must be discarded according to paragraph (d)(4)(iii)(B), Other Regulated Waste Containment, and placed in a closed container constructed to prevent spillage or protrusion of contents during handling, storage, transport, or shipping and labeled or color-coded in accordance with paragraph (g)(1)(i).

Due to the performance-oriented nature of the standard and its directive, CPL 2-2.44D, Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, it is vital that process and exposure-specific judgment is used when determining how to properly dispose of contaminated items and which disposal vehicle to use. We have enclosed two related documents that may enhance your understanding; U.S. Department of Labor News Release (February 22, 1999) and Glass Capillary Tubes: Joint Safety Advisory About Potential Risks (February 1999). Related resources are available from the OSHA Publications Office at (202) 693-1888 or your local OSHA office. Additional information is available from the Centers for Disease Control and Prevention (CDC) and the Food and Drug Administration (FDA), whose publications are disseminated without cost to you.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at If you have any further questions, please feel free to contact the Office of Health Compliance Assistance at (202) 693-2190.


Richard E. Fairfax, Director
Directorate of Compliance Programs