May 27, 2010 | | Comments 3
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Even sharps containers can benefit from a risk assessment

It’s not uncommon to see large floor model sharps containers in areas that are secured from the public, and there is certainly no regulation prohibiting these containers.

I recently received a question from a facility that had one of these sharps containers in their cardiac vascular lab, which was secured from the public. The container was open and didn’t have a feature to prevent someone from sticking their hand in or stop it from overfilling. During a survey the facility was cited for improper medical waste storage.

The manufacturer’s recommendations stated: “Store medical waste in such a manner that prevents putrefaction and also prevents infectious agents from coming in contact with the air or with individuals.”

This person wondered if this quote pertained to the storage of waste after it was removed from the room, if it was okay to leave sharps containers open in a secured area, and did the sharps containers in the lab need lids in this case?

This citation definitely falls under the realm of surveyor preference as there is no regulatory statute whatsoever that specifically prohibits the condition identified as deficient; in fact, if the condition identified were legitimately deficient, probably 75% (and perhaps more) of the sharps disposal containers used in healthcare today would be considered deficient.

For the purposes of this discussion, I’m going to contain myself (small pun intended) to the OSHA Bloodborne Pathogens standard and the CDC/NIOSH guidelines regarding sharps safety.

I’ve excerpted below the most salient passages, so let’s start with the Bloodborne Pathogens standard, specifically the section covering “Contaminated Sharps Discarding and Containment: 1910.1030(d)(4)(iii)(A).”

According to the standard, contaminated sharps shall be discarded immediately or as soon as feasible in containers that are:

  • Closable
  • Puncture resistant
  • Leakproof on sides and bottom
  • Labeled or color-coded in accordance with paragraph (g)(1)(i) of this standard

So, that’s all OSHA has to say about it; now we can certainly stipulate that OSHA really only deals with employee risk, but this would handle the exposure risk for anyone in the area.

Note that the container is required to be closable, but does not indicate a “when” for closing, except during transport. Again, if we think about the sharps disposal containers mounted on walls in hospitals all over the place, they are, in effect, open for use at all times, as much because the disposal of sharps is not necessarily a predictable event.

Let’s move on to CDC/NIOSH, which actually provides some reference to the practice:

2. Accessibility criteria

Disposal opening or access mechanism. Sharps disposal containers should be designed to permit safe disposal of sharps. They should be simple and easy to operate. The disposal opening should prevent spills of the contents (objects or liquid) while in use in the intended upright position, during the closure and sealing process, and during transportation within the user facility before final disposal. The design should also minimize any catching or snagging of sharps during insertion into the sharps disposal container. The disposal opening should be identifiable and accessible by the user and should facilitate one-handed disposal.

Security may be a concern in some areas of facilities using sharps disposal containers. For instance, to prevent children and others from putting their hands into the containers, the facility should consider selecting containers with guards that prevent hands or fingers from entering the containers. Where safety features are added to restrict child access, these features should not interfere with the worker’s vision of the inlet opening. Injury to visitors may also be a problem. Sharps disposal container options that accommodate these concerns should be available within the facility.

Clearly there is the thought/expectation that there is a risk associated because of the accessibility requirements of the design, but there is no specific prohibition. The fact that the cardiac vascular lab is not accessible by the general public, and access by the public is controlled (I’m presuming we don’t allow spectators), the risks associated with improper access are minimal. That’s not to say that it is an impossibility, but there is nothing to prevent someone from yanking a sharps disposal container off the wall of a patient room and dumping the contents on the floor to gain access to them.

You could certainly debate the relative risks of one situation to the other, but it ultimately comes down to the fact that citing improper storage does not have regulatory statute to back it up (if they had cited you for not conducting a risk assessment, they might have had a better case). The fact of the matter is that the containers are designed to provide appropriate access for disposal, and that design results in a slightly elevated risk relative to unauthorized access to the contents, but that trade-off is mitigated by using the more “open” containers only in certain areas where there is sufficient oversight to prevent any unauthorized access. In this case, I’m going to guess they haven’t experienced any instances in which someone’s “gotten in” to one of these containers, which provides performance data that the condition is being appropriately managed. If they were to experience some sort of breakdown in the future, they might have cause to reconsider the appropriateness of the strategy, but for now the evidence supports the decision.

Bottom line – no regulations say we can’t do this and our risk assessment and experience indicates that we are managing the risks appropriately.

You can find more guidance in a recent audio conference (now available on-demand), “Risk Assessments: Focus on Weak Spots and Meet Joint Commission Requirement,” in which myself and fellow Greeley colleague Bud Pate, review the general principles and implementation of a risk assessment.

Entry Information

Filed Under: CDC/infection controlOSHA

Steve MacArthur About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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  1. Steve, are these requirements the same for pharmaceutical waste? Our hospital (in California) places pharmaceutical waste in a separate container. Medications are not allowed down the drain. To be green, we are using reusable containers that close but don’t lock. We place unused medication in bags, bottles, syringes, etc in the pharmaceutical waste. If the container is in an area that is not accessable to the general public is this practice ok?

  2. Good discussion Steve. We tend to fall into the habit of believing anything that inspectors say and not really holding them to show us where they are getting this from.

    There are some areas where wall sharps are not practicle and you need a larger opening – Bone marrow biopsy area is a good example. The biopsy needle is so large that it requires a large floor mounted container with a larger opening.

    I think you point on access is the critical piece. If you have floor containers in areas where the public has uncontrolled access to, additional risk assessment and control is appropirate.

  3. Great discussion. I’m a firm believer when we encounter situations that require critical thinking and the standard might be week reading or there is no standard/code then the we need conduct and use our risk assessment tools to assist us.

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