Automated handling of reusable sharps containers
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This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.
February 21, 1995
MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS
ATTENTION: BLOODBORNE COORDINATORS
FROM: JOHN B. MILES, JR., DIRECTOR DIRECTOR OF COMPLIANCE PROGRAMS
SUBJECT: Reusable Sharps Containers
The purpose of this memorandum is to provide a reminder to the field concerning OSHA's policy on the proper handling of reusable sharps containers. Reusable sharps containers are an acceptable alternative to disposable containers and are permitted if the risk to servicing employees is eliminated.
The Occupational Exposure to Bloodborne Pathogens Standard contains a provision under the housekeeping requirements in paragraph (d)(4) that states in part that reusable containers shall not be opened, emptied, or cleaned manually. Compliance with this provision can be accomplished if the reusable containers are designed to be opened, emptied and cleaned using a fully automated system, and if such procedures are actually accomplished with that automated system in a manner which does not expose employees to the risk of percutaneous injury.
During inspections conducted in facilities where reusable sharps containers are handled, CSHOs are reminded to ensure that the facility is in compliance with the Bloodborne Pathogens standard as well as other applicable standards such as the Lockout-Tagout standard.
Should you have any questions concerning this matter, please contact [the Office of Health Enforcement at (202) 693-2190].
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[Corrected 12/6/2024]
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