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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 13, 1990

MEMORANDUM FOR:     JOHN B. MILES, JR.
                   REGIONAL ADMINISTRATOR

THROUGH:            LEO CAREY, DIRECTOR
                   OFFICE OF FIELD PROGRAMS

FROM:               PATRICIA K. CLARK, DIRECTOR DESIGNATE
                   DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Recapping Needles
This is in response to your July 17 memorandum and letter from Rosemary E. Patnode, the Northeastern Regional Industrial Hygiene Program Manager for the Department of Veterans Affairs. She inquired about the acceptability of the "one-hand scoop" method of recapping hypodermic needles.

OSHA policy is that recapping of needles, in general, is not appropriate. Used needles are to be placed in sharps disposal containers without recapping. In certain instances in which recapping is unavoidable (e.g. collection of blood for an arterial blood gas analysis), devices such as self-sheathing needles are the preferred method. Other auxiliary devices such as resheathing instruments or forceps may also be used, as may the properly performed one-hand scoop technique.

If a health care facility chooses to establish a hierarchy of preferred methods of recapping which prohibits the one-hand scoop technique, OSHA would consider that response to be an appropriate one.

Our response to Ms. Patnode's specific questions is therefore as follows:

1. Employees should not be permitted to continue routine recapping utilizing the one-hand scoop method.

2. Use of the one-hand scoop method should be limited to situations in which recapping is necessary and no preferable method is available.



July 17, 1990

MEMORANDUM FOR:    Patricia Clark, Director Designate
                  Directorate of Compliance Programs

FROM:              JOHN B. MILES, JR. Regional Administrator

SUBJECT:           Recapping Needles
Attached is a letter from Rosemary E. Patnode, the Northeastern Regional IH Program Manager for the Department of Veterans Affairs, asking about the acceptability of the "one hand scoop" method of recapping hypodermic needles. We have also enclosed two letters from this office on this subject. On the basis of conversations with Dr. Barbara Sandler/Friedman of Health Standards, we are now considering the practice to be acceptable in Region I, although to be frank we are not completely comfortable with the practice.

Since this may be a practice used nationwide at VA hospitals, we feel that it would be appropriate for an official answer to Ms. Patnode to come from your office. We will consider our policy to be an interim one until a national policy has been developed.

         U.S. Department of Labor
         Occupational Safety and Health Administration
         133 Portland Street
         Boston, MA 02114

Reply to the Attention of: OSHA/BOS/TS



July 9, 1990

MEMORANDUM FOR:     ASSISTANT DIRECTORS
                   ASSISTANT REGIONAL ADMINISTRATORS STATE DESIGNEES

FROM:               RONALD S. RATNEY Assistant Regional Administrator

SUBJECT:            Recapping needles
Recently Dave May, the Area Director in Concord, asked us to review a video tape of a procedure used at VA hospitals for recapping needles with one hand (the "one hand scoop method"). Our initial thought was that this could provide an opportunity for an employee to get stuck by the needle if it fell or moved so that it would become necessary to used both hands. In November 1989, we wrote a letter to the VA hospital in White River Junction, VT expressing these concerns.

More recently, I spoke with Barbara Sandler-Friedman, DDS who is working on the blood-borne disease standard in the National Office. She reported that she is telling callers that the one hand scoop technique is acceptable to OSHA along with certain other one handed recapping procedures although there is no written policy statement. In the interest of consistency, we will adopt this policy in Region I. We would be interested in hearing about one handed recapping procedures that your staffs observe and particularly, actual needle-stick experience with the practice.



U.S. Department of Labor
Occupational Safety and Health Administration
55 Pleasant Street
Room -334
Concord; New Hampshire 03301
(603) 225-1629

June 4, 1990

Reply to the Attention of:

TO:          John B. Miles, Jr. Regional Administrator - OSHA

FROM:        David C. May Area Director - CAO

SUBJ:        Recapping Needles at VA Hospital
The attached question from the Department of Veterans Affairs in Albany, New York, is forwarded to your office for appropriate action. We have included our video which reflects the practice of some employees who feel it is safer to recap with this method than it is to reach for the sharps container, as it occurs in the facility in White River Junction, Vermont. We had conducted an ATAR inspection at this location.

Also attached are two 1989 letters addressing the same situation for your reference when developing a response to the Department of Veterans Affairs questions.

Please keep this office informed as to OSHA's answer as we will be conducting an establishment inspection at this location later this year.

P.S. Please return the video cassette after your review.

         Regional Director
         Northeastern Region 
         Department of Labor
         P.O. Box 8500
         Veterans Affairs           
         Albany, N.Y. 12208
In Reply refer to:(10BA1)

April 26, 1990

TO:    John B. Miles, Jr.
      Regional Administrator
      Region 1 - OSHA

THRU:  David May, Area Director
      Concord Area Office
      Fed. Bldg.
      Rm 334, 55 Pleasant St.
      Concord, NH  03301

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.


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