OSHA and Sharp Medical Instruments

Understanding OSHA Requirements

By Patricia A. Trites; MPA, CHBC, CHCC, CMP™ (Hon)
Dr. Charles F. Fenton, III; JD, FACFAS
Hope Rachel Hetico; RN, MHA, CMP™

The OSHA Standard requires that contaminated needles and other contaminated sharp instruments (sharps) must not be bent, recapped, or removed.


Contaminated sharps are defined as any contaminated object that can penetrate the skin including, but not limited to: needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires.

Contaminated needles and other contaminated sharps must not be recapped or removed from the syringes unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. Also, shearing or breaking of contaminated needles is prohibited. This would include those instances, such as during surgery, where recapping was necessary due to the need to give multiple injections from the same syringe. If needles are recapped, it must be through the use of a one-handed technique.

Two-Handed Recapping

Two-handed needle recapping is strictly prohibited by the Standard. Recapping of needles can be a very dangerous procedure. It is during recapping that most skin punctures occur.

Immediately, or as soon as possible after use, contaminated reusable sharps must be discarded and placed in appropriate containers until properly reprocessed. The containers must be:

  • puncture resistant;
  • labeled or color-coded; and
  • leak proof on the sides and bottom.


Finally, containers must be at the site as close as feasible to the use of the sharps. This will limit the risk of injury during the time the sharp would otherwise have been transported from the site of use to the site of disposal. During use, the sharps container must be maintained upright, not be allowed to be overfilled, and replaced routinely. When moving containers of contaminated sharps from the area of use, the containers must be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling. The container must be placed in a secondary container if leakage is possible. Reusable containers must not be opened, emptied, or cleaned manually or in any other manner that would expose employees to the risk of percutaneous injury. Physicians can purchase turn-key sharps containers that, when full, can be shipped back to the distributor for proper disposal.



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6 Responses

  1. Patricia,

    Medical students are frequently stuck by needles, and few report their accidents, researchers say.

    In a new survey, about 60% of surgery residents reported being stuck with a needle while they were in medical school, Martin A. Makary, MD, MPH, of Johns Hopkins, and colleagues reported in the December issue of Academic Medicine.

    “Needlestick injuries during medical school among students who go on to surgery residencies are highly prevalent and likely are under-reported,” the researchers wrote.


    Nice job on the post.


  2. Grant,

    The Needlestick Safety & Prevention Act of 1999 mandates that safety devices be used on all needles, syringes, scalpels, lancets, butterfies, and other sharps except in extraordinary circumstances. The fine for not having or not activating the safety devices is up to $70,000 per occurrence. This includes phlebotomy single-use tube holders.

    The requirements for a needlestick safety committee and process for assessing products are outlined by OSHA and should be included in a practice’s on-site manual.

    Further information on this aspect of OSHA is available at http://www.osha.gov/needlesticks/needlefaq.html

    Susan Theuns PA-C
    [Baltimore, Maryland]


  3. A New ThumBlade® Safety System with Video Presentation

    This new system features an innovative thumb activation mechanism for scalpel safety that enables one-handed activation by right or left handed practitioners with no contact with the exposed blade.

    The system’s performance is predicated on extra-sharp blades and re-usable stainless steel handles; in addition, a creative pricing program gives it the usage cost of throw-away plastic handle scalpels.

    For more info: http://www.pmdmfg.com/



  4. Hi Dan,

    Your comment seems a bit too promotional for me, but if it saves cuts and lives, so be it.



  5. Jake,
    Thanks for your honesty. Rest assured, I have no “dog in this fight”.


  6. Thousands at HIV risk from dentist’s reused syringes and needles in Colordao

    A suspended Colorado dentist reused syringes and needles in his now-shuttered practice, potentially exposing thousands of patients to HIV and hepatitis infection, health officials just warned on Friday.




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