Q. We generate contaminated sharps at several locations in our facility. We are currently using a large plastic pail that is centrally located in the building to collect all of these sharps, but I’ve been told that we can’t do that. What kinds of containers do we have to use and where are we supposed to place them? Also, where are we supposed to send them when they are full?
A. In general, one centrally located sharps container would not meet the requirements of OSHA’s bloodborne pathogen standard. According to 29 CFR 1910.1030(d)(4)(iii)(A)(1), contaminated sharps must be discarded “immediately or as soon as feasible.” In addition, containers for contaminated sharps must be “easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found (e.g., laundries).” [emphasis added by Lion] Depending on the size of your facility and the location of the areas where the sharps are being generated, employees may be required to walk considerable distances to reach a centrally located sharps container, and it is likely that it would be “feasible” for containers to be located closer to the actual points of generation.
The use of a plastic pail in which to collect contaminated sharps might or might not be acceptable under the bloodborne pathogen standard. The standard requires that containers used to collect contaminated sharps be closable, puncture resistant, leakproof on the sides and bottom, and labeled with the “BIOHAZARD” symbol or color-coded red [29 CFR 1910.1030(d)(4)(iii)(A)(1)(i) - (iv) and 1910.1030(d)(1)(i)]. So even though many facilities choose to use specially designed red sharps containers to collect contaminated sharps, any container that meets the above requirements would actually be acceptable to use.
Containers used to collect contaminated sharps must be replaced regularly and should not be allowed to overfill. When the time comes to move them, they must be closed immediately prior to removal or replacement to prevent spillage during handling, storage, transport, or shipping. If leakage is possible, then they should be placed in a secondary container that is closable, constructed to contain all contents, and labeled with the “BIOHAZARD” symbol or color-coded red [29 CFR 1910.1030(d)(4)(iii)(A)(3)]. Reusable containers are not allowed to be manually opened, emptied, or cleaned, or handled in any other way that would expose an employee to the risk of an injury from the contaminated sharp [29 CFR 1910.1030(d)(4)(iii)(A)(4)].
With regard to the ultimate disposition of the contaminated sharps, OSHA has stated that the disposal of all regulated waste must be in accordance with applicable regulations of the United States, states and territories, and political subdivisions of states and territories. Because different states will have their own rules for what is considered acceptable measures of treatment of regulated waste prior to final disposal, you should contact your state for guidance on their requirements.