Needle sheath for recapping and sharps disposal

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 6, 1990

Mr. William M. Teringo
PDMP, Inc.
[Recipient address omitted]
Dear Mr. Teringo:

This is in further response to your letter of May 16 in which you requested information on the ability of your Nonmechanical Incapacitation Syringe Safety Needle Sheath to satisfy Occupational Safety and Health Administration (OSHA) requirements. Our response to your questions is as follows:

Question 1: Because of OSHA recommended guidelines as to recapping of used syringes with original needle guard, will the needle sheath described, which is designed with a cone shaped finger protector of three quarters (3/4") diameter, be sufficient to satisfy OSHA requirements?

OSHA Instruction CPL 2-2.44B, "Enforcement Procedures for Occupational Exposure to Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV)" clarifies OSHA's prohibition against recapping and expressly allows recapping by some method other than the traditional two-handed procedure, i.e., the use of resheathing instruments, self sheathing needles, or forceps is permitted.

The finger protector described in your letter as being three-quarters of an inch in diameter does not adequately protect the hand holding the needle sheath from accidental puncture. Since the three-quarters of an inch diameter leaves much of the hand area uncovered, OSHA cannot consider it acceptable protection for use with a two-handed recapping procedure.

Question 2: Based on the current methods of handling used syringes by encasing them in a plastic container, can the needle sheath described be considered as a waste container?

While disabling the syringe with adhesive appears to be a good idea, OSHA views its use as a temporary measure, suitable for use by emergency medical technicians or home health care workers. Since there is no guarantee of correct usage or proper function of the device, the needle should still be disposed of in a sharps container.

We hope this information is responsive to your concerns.

Sincerely,
Gerard F. Scannell
Assistant Secretary

[Undated interim OSHA reply, requester letter, and device description reproduced on OSHA page; omitted here.]