Two-handed needle recapping device review

January 26, 1993

Douglas A. Witte, DDS
Periodontics
[Recipient address omitted]
Dear Mr. Witte:

This is in response to your letter of November 10, addressed to Gilbert Saulter, Regional Administrator in Dallas. You requested clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens". Specifically, you asked if the recapping device you submitted, Safe-Cap, meets the intent of the standard.

As you know, the standard prohibits recapping of contaminated needles unless recapping is required by a specific medical procedure or unless no alternative is feasible. If recapping must be performed, it must be accomplished by means of a recapping device which adequately protects the hands or a properly performed one hand scoop technique.

In general, OSHA does not review products as you have requested and the agency does not endorse or approve products. 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 on their own.

In this case no accompanying literature or description of the device was submitted for us to consult. For example, once the device is adjusted to hold a particular size cap it is unclear how a new adjustment is to be made to accommodate a larger cap. It appears, from our cursory review, that the device would not meet the intent of the standard as it does not adequately protect the hand holding the device from accidental puncture. Employees may place their hand anywhere along the length of the device, including at a point in close proximity to the cap. In such a case OSHA could not consider it to provide acceptable protection for use with a two-handed recapping procedure.

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

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

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