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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 10, 1991

Patricia Seigel, RN
Assistant Nursing Supervisor
Garden State Medical Group, P.A.
Paramus Center
[Recipient address omitted]
Dear Ms. Seigel:

Thank you for your letter of May 13, in which you requested clarification on the Occupational Safety and Health Administration (OSHA) requirements regarding recapping of used needles.

On February 27, 1990, OSHA issued a revised compliance directive to its field staff entitled OSHA Instruction CPL 2-2.44B, "Enforcement Procedures for Occupational Exposure to Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV)". A copy of this Instruction is enclosed for your information. On page 16, you will see that OSHA has clarified its prohibition against recapping by hand.

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, such as the situations you describe, recapping by some method other than the traditional two-handed procedure is permitted. Acceptable methods include the use of self-sheathing needles or other auxiliary devices such as resheathing instruments or forceps. The properly performed one- hand scoop technique may also be used.

With regard to your proposal to set up containers in each room for "unused sharps", it is unclear why your facility would choose to segregate used sharps. While OSHA requires that used sharps be disposed of in regular sharps containers, the ultimate disposal method (landfilling, incinerating, and so forth) for medical waste falls under the purview of the U.S. Environmental Protection Agency (EPA) and possibly state and local regulations. It is our understanding of the EPA Medical Waste Tracking Act that, in New Jersey, used needles are considered regulated medical waste regardless of the presence of infectious agents. You may wish to contact your local EPA office for further information.

If you would like to further discuss the specifics of your facility with OSHA, we suggest that you contact OSHA's bloodborne disease coordinator for the New York Region at (212) 337-2325.

We hope this information is responsive to your concerns and we thank you for your interest in worker safety and health.

Sincerely,
Gerard F. Scannell
Assistant Secretary

Enclosure

[The requester's May 13, 1991 letter reproduced on the OSHA page is omitted here.]