Standard Interpretations - Table of Contents
• Standard Number: 1910.1030(d)(2)(vii)(A)

June 12, 2002

Mr. Douglas E. Kline
Infection Control Practitioner
1101 Wellesley Terrace
Westchester, PA 19382


Dear Mr. Kline:

Thank you for your March 20, 2001 letter to the Occupational Safety and Health Administration (OSHA) regarding the applicability of OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) to the safe practice of phlebotomy and blood tube holder use. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

We apologize for the extreme delay in our response to you. As you know, based on your phone conversations with our staff, we were awaiting the release of the revised compliance directive (CPL 2-2.69, November 2001) to address similar issues with sweeping national implications. Removing contaminated needles in order to re-use blood tube holders has gained more national attention, and we felt it best to address such an important issue first in our compliance directive. You can access that document on the World Wide Web [http://www.osha.gov/OshDoc/Directive_pdf/CPL_2-2_69.pdf].

Thank you for your understanding in this matter. Your question is summarized below followed by OSHA's interpretation.

Question: What is OSHA's position regarding the use of blood tube holders, specifically removing a needle in order to re-use a tube holder? Must each blood tube collection device be disposed of with the needle attached each time they are used?

OSHA's Bloodborne Pathogens Standard (29 CFR1910.1030, paragraph (d)(2)(vii)(A)) provides: “Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed, unless the employer can demo