OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
November 21, 1989
MEMORANDUM FOR: JACKIE ROGERS
Office of Health Compliance Assistance
THRU: STEVE MALLINGER Deputy
Directorate of Technical Support
FROM: Pat Bertsche
Directorate of Technical Support
SUBJECT: 1. Life-GARD needle shield by Willander
2. The Recapper by Atomic Products Corporation
I have been sent two syringe recapping devices by OSHA field personnel to render a professional opinion as to the effectiveness of the devices. As you well know, OSHA Instruction CPL 2-2.44A, subject: Enforcement Procedures for Occupational Exposure to HBV and HIV, states that needles shall not be recapped by hand.
I consulted with personnel in the Directorate of Health Standards Program who are currently working on the development of the bloodborne pathogens standard regarding these two devices.
It is my opinion, and the opinion of Health Standards personnel, that the Life-GARD needle recapping device will not provide adequate protection since the shield is not big enough to cover the entire hand, especially a large hand.
The Recapper syringe recapping device appears to provide adequate protection for larger gauge needles. I unsuccessfully tried recapping a 1cc 25G 5/8 tuberculin syringe and needle with the Recapper. Therefore, the device should only be used with larger gauge needles.