Sharps Containers: The Point of Compliance
by Gracie Hogue, BM
One of the “small” details that is a big deal to OSHA is sharps containers. In some practices we at MPS have inspected, we’ve found sharps containers in places like cabinets, treatment room corners, and on countertops. OSHA has standards for sharps containers that if left unfollowed could result in costly OSHA fines. Since disposal is usually the main occasion for contaminated needle sticks to happen (according to CDC’s Workbook for Designing, Implementing, and Evaluating a Sharps Injury Prevention Program,) OSHA pays close attention to how sharps containers are placed and handled.
See CDC’s workbook here:
If you’re at all unsure about your sharps containers, take a walk through your practice and compare the placement of the sharps containers to this list of required compliance:
- Size: OSHA doesn’t specify a certain required size; only that the “Employers should select the appropriate container design after assessing the hazards associated with use of sharps containers (e.g., considering the size and types of contaminated sharps the employer expects to dispose of),” according to recommendations from the National Institute for Occupational Safety and Health (NIOSH) document, Selecting, Evaluating, and Using Sharps Disposal Containers. OSHA's Bloodborne Pathogens standard at 29 CFR 1910.1030 (d)(4)(iii)(A)(l)(i) requires that sharps containers be closable, but does not specify a set size for the opening on a container to be.
- Material: There is not a specific material specified by OSHA, but: “Containers for contaminated sharps must be puncture-resistant. The sides and the bottom must be leakproof. They must be appropriately labeled or color-coded red to warn everyone that the contents are hazardous. Containers for disposable sharps must be closable (that is, have a lid, flap, door, or other means of closing the container), and they must be kept upright to keep the sharps and any liquids from spilling out of the container.” (Reference: OSHA Fact Sheet Protecting Yourself When Handling Contaminated Sharps.)
- Placement: This is where OSHA gets pretty specific. Sharps containers can’t be placed just anywhere. According to NIOSH and OSHA 1910-1040(g)(1)(i)(D).): “Sharps containers are to be located near the hazard, within arm’s reach and placed at height that is below eye level for users (typically 52 – 56 inches from the floor when wall mounted or 38 – 42 inches for a seated workstation).”
It obviously needs to be kept in a secure place where it cannot be jostled or easily knocked down or turned over. According to CDC guidelines: “Containers should be upright and easy to operate while preventing the contents from spilling. The container should be placed in a visible location, within easy horizontal reach, and below eye level. The container should also be placed away from any obstructed areas, such as near doors, under sinks, near light switches, etc.”
NIOSH has a list of inappropriate places for sharps containers. Those inappropriate places include:
- The corner(s) of a room
- Mounted on the back of a door
- Under cabinets
- Mounted on the inside of cabinet doors
- Under sinks
- In areas where a patient or person could sit or lie directly beneath the sharps container
- Near a light switch, environmental controls, or electrical outlets
- Where the container could possibly be in contact with a pedestrian or in practice traffic or moving equipment
- Care: “The containers must be replaced routinely and not be overfilled, which can increase the risk of needlesticks or cuts. Sharps disposal containers that are reusable must not be opened, emptied, or cleaned manually or in any other manner that would expose workers to the risk of sharps injury. Employers also must ensure that reusable sharps that are contaminated are not stored or processed in a manner that requires workers to reach by hand into the containers where these sharps have been placed.” (Reference: OSHA Fact Sheet Protecting Yourself When Handling Contaminated Sharps.)
- Handling: “Before sharps disposal containers are removed or replaced, they must be closed to prevent spilling the contents. If there is a chance of leakage from the disposal container, the employer must ensure that it is placed in a secondary container that is closable, appropriately labeled or color-coded red, and constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping.” (Reference: OSHA Fact Sheet Protecting Yourself When Handling Contaminated Sharps.)
Being sure your sharps containers are made, placed, and handled correctly also ensures you that risk of injury and infection in your practice being significantly lessened.