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.

September 25, 1997

Mr. William M. Wagner, President
Hospital Waste Management, Inc.
249 Hardage Drive
Marietta, GA 30064

Dear Mr. Wagner:

This is in response to your letter dated July 28, 1997, concerning further clarification of the Safe Medical Systems' SNR sharps collection system. You have asked for an interpretation as it pertains to the "shearing" action of the SNR, and whether the shearing of the plastic end of the syringe is prohibited by the Occupational Safety and Health Administration's Occupational Exposure to Bloodborne Pathogen standard (CFR 1910.1030).

The system for needle disposal you described in a previous letter is a system that shears the plastic end of the syringe holding the needle. The sheared end with the needle then falls into a sharps container. The shearing of the plastic syringe is not prohibited by the standard. The standard does prohibit the shearing of the needle. As discussed in the previous letter, the remaining parts of the syringe and plunger are contaminated and must be properly disposed of as well.

I hope this letter has fully addressed your request for clarification of the Bloodborne Pathogen standard. If you have further questions, please call Wanda Bissell of my staff at (202) 219-8036 ext. 49.

Sincerely,

Stephen Mallinger, Acting Director
Office of Health Compliance Assistance