Ezel / Labor Guidance / US
Back to Federal guidance

Effectiveness of two syringe recapping devices

Summary OSHA technical staff reviewed two syringe recapping devices for field personnel. They considered one shield too small to protect the whole hand and found the other suitable only for larger gauge needles based on their trial. The memorandum gives a device-specific opinion under a then-current enforcement instruction; OSHA now archives it as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-11-21
Date issued
November 21, 1989
Status
Archived by the agency
OSHA archives this memorandum and says it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Bloodborne Pathogens Sharps Safety
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

The current status of this document is unclear
OSHA archives this memorandum and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 21, 1989

MEMORANDUM FOR: JACKIE ROGERS
Office of Health Compliance Assistance

THRU: STEVE MALLINGER Deputy
Directorate of Technical Support

FROM: Pat Bertsche
Directorate of Technical Support

SUBJECT: 1. Life-GARD needle shield by Willander
2. The Recapper by Atomic Products Corporation

I have been sent two syringe recapping devices by OSHA field personnel to render a professional opinion as to the effectiveness of the devices. As you well know, OSHA Instruction CPL 2-2.44A, subject: Enforcement Procedures for Occupational Exposure to HBV and HIV, states that needles shall not be recapped by hand.

I consulted with personnel in the Directorate of Health Standards Program who are currently working on the development of the bloodborne pathogens standard regarding these two devices.

It is my opinion, and the opinion of Health Standards personnel, that the Life-GARD needle recapping device will not provide adequate protection since the shield is not big enough to cover the entire hand, especially a large hand.

The Recapper syringe recapping device appears to provide adequate protection for larger gauge needles. I unsuccessfully tried recapping a 1cc 25G 5/8 tuberculin syringe and needle with the Recapper. Therefore, the device should only be used with larger gauge needles.

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace