Needleless syringe device use in home health care

October 13, 1994

Mr. Andrew Rowjohn
Director, Quality Assurance and Regulatory Affairs, Becton Dickinson Consumer Products
[Recipient address omitted]
Dear Mr. Rowjohn:

Thank you for you letter of June 1, concerning the Occupational Safety and Health Administration's (OSHA) requirements for sharps containers under the Bloodborne Pathogens Standard (29 CFR 1910.1030). Your product (B-D Safe Clip) is described as a home product, and not intended for professional use. Therefore, the Bloodborne Pathogens standard may not apply to your product, because the standard is only applicable to the occupational setting.

As you know, employees can work in the home. For example, employees of a home health care service would be covered by the standard. And consequently, under those circumstances of occupational use the B-D Safe Clip would have to meet the requirements for sharps containers under the standard.

We hope that this response addresses your concerns. If you have any further questions, please feel free to contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,

Ruth E. McCully, Director Office of Health Compliance Assistance

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[Corrected 12/6/2024]