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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 https://www.osha.gov.
June 29, 2007
Mr. Keith Dill
15705 Emeline Street
Omaha, NE 68105
Dear Mr. Dill:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Enforcement Programs (DEP) for a response. You inquired about the appropriateness of your disposal of used insulin syringes in your regular office trash. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. For clarification, your specific questions are paraphrased below, followed by OSHA's response.
Question: Is it considered a violation of the OSHA Bloodborne Pathogens standard for diabetic who self-administer insulin at work to dispose of capped insulin syringes in an office trash container?
Reply: The Bloodborne Pathogens Standard, 29 CFR 1910.1030, does not apply to the self-administration of insulin by employees or their disposal of insulin syringes used for self-administration except at places otherwise covered by the standard, such as health care facilities, industrial first aid units, and laboratories. Thus, the use and disposal of such syringes at the typical office, such as a call center, would not be covered. Improper disposal of insulin needles however, can create a safety hazard for maintenance workers, waste handlers, and janitors who must later handle the office trash placing them at risk for exposures to bloodborne pathogens including HIV/AIDS, hepatitis B, and hepatitis C from needlestick injuries. Therefore, OSHA recommends that employers require insulin-using employees to discard their used syringes in special containers rather than allowing them to be discarded in regular office trash. There are commercially available sharps containers and needle destruction devices manufactured and marketed for home use which would be appropriate in this scenario.
Additionally, there are a number of community sharps disposal programs operated through community organizations, local health departments, fire departments, hospitals, health clinics, and pharmacies which act as designated drop-off sites for filled sharps containers used by residents who self-inject. Many of these community programs offer free sealable containers made of rigid, puncture-resistant plastic, for self-injectors to use and return when full. These programs help in reducing the number of used needles that enter the regular trash and minimize the potential for waste handlers to get stuck by used needles. In lieu of a locally available community sharps disposal program, public health officials advise self-injectors to use approved household containers to collect used syringes which might then be accepted for disposal in municipal household hazardous waste collection sites. The Environmental Protection Agency (EPA) has published informational brochures on various community options for safe needle disposal which are publicly available on EPA's website at http://www.epa.gov.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Richard E. Fairfax
Directorate of Enforcement Programs