Needle resheathing device and two-handed recapping protection

October 2, 1992

Ms. Margaret Flanagan-Wilkie
Hart Healthcare Industries, Inc.
[Recipient address omitted]
Dear Ms. Flanagan-Wilkie:

This is in response to your letter of July 31 requesting clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Specifically, you asked if your StopStix resheathing device meets the intent of the standard.

In general, OSHA does not review products as you have requested. The final determination of compliance must take into account all factors pertaining to the use of such devices at a particular worksite. This must include an evaluation through direct observation of employee work practices as well as an evaluation of the equipment or devices alone.

In this case, however, we must inform you that the StopStix does not meet the intent of the standard as it does not adequately protect the hand holding the protector from accidental puncture. Since the diameter of the StopStix finger protector leaves much of the hand area uncovered, OSHA cannot consider it acceptable protection for use with a two-handed recapping procedure.

Sincerely,
Roger A. Clark,
Acting Director
Directorate of Compliance Programs