Sharps disposal container review and OSHA endorsement

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 8, 1990

Mr. Michael R. Anderson, Director of Marketing, Hemox, Inc.
[Recipient address omitted]
Dear Mr. Anderson:

This is in response to your letter of June 12, addressed to Jessica Sandler of my staff. You requested that she review the literature associated with your Hemox Safe Deposit System and the product itself and provide you with her opinion of it.

As Ms. Sandler has discussed with you, the Occupational Safety and Health Administration (OSHA) does not endorse or approve any particular type of product or medical device. The current compliance directive (OSHA Instruction CPL 2-2.44B: "Enforcement Procedures for Occupational Exposure to Hepatitis B Virus and Human Immunodeficiency Virus") requires that sharp items be placed in puncture-resistant containers for disposal. The proposed standard on Occupational Exposure to Bloodborne Pathogens requires that the containers be closable, puncture-resistant, and leakproof on the sides and bottom as well as appropriately labeled or color-coded.

Your "Safe Deposit System" appears to comply with the intent of the current OSHA requirements. Of course, the final determination regarding compliance with OSHA's requirements in the area of bloodborne hazards must be made in the workplace by direct OSHA compliance officer observation of employee work practices while utilizing your product.

I hope this information is helpful to you.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]