OSHA Addresses Restraining Mechanisms for Sharps Containers

In an April 18, 2008, Letter of Interpretation posted to OSHA's Web site Dec. 4, the agency addresses the placement of sharps containers in facilities and the requirement to ensure they are maintained in an upright position.

Specifically, the agency responded to this question: "In a laboratory where sharps containers are kept close to employees' workstations with lids and are positioned so that they are kept upright, is it necessary to have 'mechanisms' to restrain the containers as a precaution from spillage?"

Richard E. Fairfax, director of OSHA's Enforcement Program Directorate, pointed out that 29 CFR 1910.1030(d)(4)(iii)(A)(2)(ii) requires that, during use, containers for contaminated sharps must be "[m]aintained upright throughout use" and that the use of mechanisms to restrain sharps is one way of preventing spillage during use. He added, however, that the agency's bloodborne pathogens standard does not specify the use of restraining mechanisms for all situations of sharps container use.

"For example, if a workplace assessment reveals that sharps containers can be maintained in an upright position during use with no danger of being knocked over or spilled, or that the containers must remain unrestrained to accommodate mobility needs, or employees or patients might be endangered by fixed sharps containers (e.g., in a mental health or correctional facility), the use of restraining mechanisms would not be mandatory," Fairfax wrote. "The placement of sharps containers, as well as the measures used to maintain them in an upright position during use, must be based on the site-specific hazard assessment of the area of intended use."

Fairfax noted that NIOSH's "Selecting, Evaluating, and Using Sharps Disposal Containers" document recommends important components of a site-specific hazard analysis in the selection of sharps containers, including

  • container transport or mobility needs;
  • clinician and procedural variability and movement; and
  • laboratory equipment variability and movement.

"If, after evaluating the work environment, an employer determines that restraining mechanisms are not required, but makes the decision to install them as an added measure to ensure the sharps containers are maintained upright, doing so should not, in itself, create an unsafe or unhealthful condition," Fairfax wrote.

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