Disposal and recapping of used radiopharmacy syringes

August 25, 1993

Mr. Don Reich,
Program Manager
Syncor International Corporation
[Recipient address omitted]
Dear Mr. Reich:

This is in response to your letter of July 9, regarding the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." You asked several questions relative to the unit dose syringes your company delivers to hospital nuclear pharmacy departments. We will answer your questions in the order presented in your letter.

Question 1: "Do the used syringes and needles meet the definition of a contaminated sharp and/or regulated waste?"

Answer: Because the prescription-containing needles are injected into patients, the used needles would be considered contaminated sharps. All contaminated sharps and syringes are to be disposed of as regulated waste.

Question 2: "Are the handling and disposal practices of this waste regulated under 1910.1030?"

Answer: Yes, section (d)(4)(iii)(A) specifies the discarding and containment requirements for contaminated sharps. Paragraph (d)(4)(iii)(C) states that disposal of all regulated waste shall be in accordance with applicable regulations of the United States, States and Territories, and political subdivisions of States and Territories.

Question 3: "Would the generator of this waste be required to comply with the regulated waste provisions of 1910.1030?"

Answer: Yes.

Question 4: "Would the recapping of a used needle be allowed under the provisions of 1910.1030?"

Answer: Paragraph (d)(2)(vii)(A) states that contaminated needles and other contaminated sharps shall not be bent, recapped, or removed unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. Recapping needles to be returned to the manufacturer for disposal would not qualify for either exception and would be prohibited.

Question 5: "Would the extra handling step of placing the used syringes in the DOT container and then dumping the syringes in another disposal container be allowed under the provisions of 1910.1030?"

Answer: The transfer of contaminated sharps from one container to another is not permitted under the bloodborne pathogens standard. However, sharps containers may be placed into a larger secondary container without emptying the contents.

We hope this information has been responsive to your concerns. Thank you for your interest in employee safety and health.

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

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