Q: What guidance does OSHA give on recapping fill needles?
A: OSHA is pretty blunt about recapping needles – they don’t recommend it!
Let me address the recapping of needles into categories:
A) Contaminated needles
The Bloodborne Pathogens standard section (d)(2)(vii) : “Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed…” The violation of the OSHA standard could not only injure staff members but also cost it as much as $7,000 as a serious fine, as classified by OSHA. If an employer continues this practice, it could become a willful fine, which ups the ante to $70,000.
B) Non-contaminated Needles
The standard strictly prohibits bending, recapping, or removal of contaminated sharps unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure. [29 CFR 1910.1030(d)(2)(vii)(A)] The standard does not focus on the recapping of non-contaminated needles. However, the health and safety of both the clinician and the patient are important. It would be important not to recap the needle and risk the health care worker being contaminated with the medication that is in the fill syringe. It is equally as important not to contaminate the needle with the healthcare worker’s skin, because this would provide risk to the patient.
The standard requires each employer to establish an exposure control plan “designed to eliminate or minimize employee exposure.” If the medical practices require recapping or removal of sharps or if no alternative, such as immediate discarding into an approved sharps container, is feasible, the exposure control plan must include a provision for the use of mechanical devices in these circumstances. Although OSHA cannot, of course, approve or endorse particular products, there are a number of acceptable mechanical recapping devices.
Editor’s note: This Q&A was answered by Ron Stoker, executive director of the International Sharps Injury Prevention Society (ISIPS), Harriman, UT. www.isips.org