They are sharps, after all, so isn’t an extra layer of safety in disposal necessary? As experts at Safety.BLR.com® pointed out in an Ask the Expert question, the trash isn’t technically the proper disposal method—but by the same token, OSHA rules do not mandate that employers address syringes for personal use, which insulin injections would fall under.
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The proper disposal method is to place the used needle in a special sharps container for disposal to avoid contamination if someone (e.g., janitor or housekeeper) is accidentally stuck with the needle. However, the employer is not mandated by OSHA rules to do this concerning syringes for personal use.
Following is an excerpt from an OSHA bloodborne pathogens interpretation letter dated March 23, 2001, concerning insulin needles:
“The Bloodborne Pathogens Standard only applies to occupational exposure to blood. The employer would not be required to provide a sharps container to an employee using insulin syringes for personal therapeutic reasons. In order to eliminate potential exposures to other workers, the employer should strongly insist that the employee have his or her own sharps container and bring that with them to the workplace.”
A later OSHA letter of interpretation, dated June 29, 2007, further reinforced that the Bloodborne Pathogens Standard does not apply in this situation unless the employee works in a particular industry or facility. “The Bloodborne Pathogens Standard, 29 CFR 1910.1030, does not apply to the self-administration of insulin by employees or their disposal of insulin syringes used for self-administration except at places otherwise covered by the standard, such as health care facilities, industrial first aid units, and laboratories,” the letter notes.
The 2007 letter also provides some useful guidance for employers who are looking to encourage diabetic employees to have sharps containers on hand for disposal of Insulin syringes:
“… there are a number of community sharps disposal programs operated through community organizations, local health departments, fire departments, hospitals, health clinics, and pharmacies which act as designated drop-off sites for filled sharps containers used by residents who self-inject. Many of these community programs offer free sealable containers made of rigid, puncture-resistant plastic, for self-injectors to use and return when full. These programs help in reducing the number of used needles that enter the regular trash and minimize the potential for waste handlers to get stuck by used needles. In lieu of a locally available community sharps disposal program, public health officials advise self-injectors to use approved household containers to collect used syringes which might then be accepted for disposal in municipal household hazardous waste collection sites. The Environmental Protection Agency (EPA) has published informational brochures on various community options for safe needle disposal which are publicly available on EPA’s website.”
For other workplace considerations and accommodations with regards to diabetes, such as the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA), you can find additional information on our sister publication, the HR Daily Advisor, here and here.