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Pricey Mr. Savona:

Thank you in your November 24, 2009, letter to the Occupational Security and Well being Administration (OSHA). Your letter was forwarded to OSHA’s Directorate of Enforcement Packages (DEP) for a response. This letter constitutes OSHA’s interpretation solely of the requirements discussed and is probably not applicable to any question(s) not delineated inside your authentic correspondence. For clarification, your query is paraphrased below adopted by OSHA’s responses.

Query 1: Does the OSHA requirement for sharps containers to be “closable” [29 CFR 1910.1030 (d)(4)(iii)(A)(l)(i)] permit employers to maintain your complete lid on a sharps container open throughout use, closing it only after the container is full or should the small opening on the lid of the container be used for depositing all contaminated sharps (instead of your entire lid) and then closed when the container is full?

Reply 1: The disposal opening on a sharps container ought to be of a dimension and design that would permit protected disposal of sharps. OSHA’s Bloodborne Pathogens standard at 29 CFR 1910.1030 (d)(4)(iii)(A)(l)(i) requires that sharps containers be closable, however does not specify a set size for the opening on a container to be. Sharps containers are used for disposal of contaminated sharps of varied sizes and configurations. Therefore, OSHA has not decided that any single sharps container design is appropriate for all services or for all areas of use within a given facility.

In response to recommendations from the Nationwide Institute for Occupational Security and Health (NIOSH) document, Deciding on, Evaluating, and Using Sharps Disposal Containers, the selection of a sharps container ought to be based on a site-specific hazard analysis. Generally, when containers having small opening(s) on the lid are chosen for use, the employer has based such a variety on a determination that the configuration of the opening(s) would accommodate the largest sharp being used in the actual workstation/location. In situations the place the small opening on the lid of the container is of adequate size to accommodate all sharps requiring disposal, there needs to be no want for the complete lid to be opened. Employers should choose the appropriate container design after assessing the hazards related to use of sharps containers (e.g., contemplating the scale and kinds of contaminated sharps the employer expects to dispose of). If the employer is finding the necessity to open your complete lid, maybe further analysis is required to guarantee that the container chosen is appropriate to accommodate sharps of all sorts and sizes that require needle disposal box. It is likely that a container of a special measurement, kind or design configuration can be extra appropriate in the particular situation of use.

Thanks for your curiosity in occupational safety and health. We hope you find this info useful. OSHA necessities are set by statute, standards, and laws. Our interpretation letters explain these necessities and how they apply to specific circumstances, however they can not create further employer obligations. This letter constitutes OSHA’s interpretation of the necessities mentioned. Also, on occasion we replace our steering in response to new information. Notice that our enforcement guidance may be affected by modifications to OSHA rules. To maintain apprised of such developments, you possibly can consult OSHA’s webpage at http://www.osha.gov. If you have any further questions, please be happy to contact the Workplace of Well being Enforcement at 202-693-2190.