US Requirements for Sharps Containers Reviewed: Jan 14th 2013 (TG) 1. FDA Regulations Yes/ No All sharps containers 510(k) available Compliant with CFR 21 Part 820 Quality System Regulation and Good Manufacturing Practices. Labeled with clear directions for safe use OSHA compliant (Closable, Puncture resistant. Label/colorcoded, Leak resistant when upright) Puncture Resistant (base, sides, closure, top) Reusable Sharps Containers 510(k) performance tests included: o Repeated filling and emptying container of sharps, equal to stated lifespan-uses, using normal processing o DOT Vibration test Passes Impact Resistance, Puncture Test, Leak Test after above lifespan-use simulation 2. DOT Regulations All sharps containers DOT UN Specification Packaging Tests (Containers <20gall Exempt): o Drop test (1.2m/4ft, -18C/0F) o Stacking Strength Test (3m high, 24hrs, 40C/104F) o Stacking Stability Test (3 containers high, 1 hr, ambient temp.) o Vibration test. Marked appropriately if represented as meeting UN Standard Leakproof in all orientations (DOT requirement June 2006) Secure closure preventing leaks or punctures Puncture resistant Visible Biohazard symbol or Infectious Substance Label, in contrasting color with background Labelled with proper UN Shipping Name & Number Reusable Sharps Containers Container capacity between 2-40 galls (7.57-151.42 L) in vol. Permanently marked for reuse Approved & certified by U.S. FDA as a medical device for reuse Disinfected prior to reuse, effective for infectious substance previously contained. Yes/ No 3. OSHA Regulations Yes/ No All sharps containers Decision process enables non-managerial employees to identify, evaluate and select sharps containment system Containers shall be: o Closable o Puncture resistant o Leakproof on sides and bottom o Labeled/color-coded to BBP standard. During use, containers shall be: o 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); o Closed immediately prior to removal or replacement o Replaced routinely and not allowed to overfill o Maintained upright throughout use Needle unwinders on containers are general prohibited. During container movement: o Containers shall be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping o Containers shall show no sign of leakage of fluids during handling, storage, transport, or shipping o If container cannot be sealed to prevent leakage it must be placed in a leakproof secondary container constructed to contain all contents during handling, storage, transport or shipping. Reusable Sharps Containers During Processing, reusable containers shall: o Be cleaned and decontaminated such that they are rendered safe for reuse o Not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of percutaneous injury o Examined and maintained or replaced on a regular schedule to ensure their physical, mechanical or replacementdependent controls are functioning as intended. 4. ASTM Standard F2132-01 (2008)e1 All areas of differing thickness/material on sharps container (including base, sides, closure, top) meet Penetration Test Yes/ No 5. NIOSH Guideline Functionality Stable on horizontal surfaces and when used in manufacturer’s holders Puncture resistant Leak resistant on sides and bottom Impact resistant Durable labels, warnings, brackets and locking mechanisms Autoclavable, if necessary Available in various sizes and capacities to accommodate volume of sharps generated Restricted access to sharps in container Closure mechanism does not allow needlestick injury during engagement or transport Closure mechanism provides secure seal Design minimizes needle-tip flipback Promotes clinical performance, e.g. does not compromise sterile field or increase injury or infection control hazards Resists easy reopening after sealing Inlet defeats waste removal when open Inlet defeats spillage while in use in intended upright position If re-openable, has tight closure that facilitates ease of opening with grip safety and comfort Mounting brackets are rugged, easy to service & decontaminate Accessibility Available in various opening sizes and shapes Entanglement-free opening Opening and fill status visible to user Design does not impede ease of use Handles: o Are located above fill-line o Facilitate safe vertical transport o Are located away from opening o Are located away from potentially soiled surfaces Can be fixed within arm's reach of sharps generation Can be fixed below horizontal vision level i.e. allows user to see into inlet opening Secure against tampering in high patient or visitor traffic areas Agree 1 Disagree 2 3 4 5 NIOSH (contin.) Visibility Color or warning label implies danger Warning color/label readily visible to users Overfill and current fill status readily visible to user Complies with OSHA requirements Inlet opening visible to user Security, mounting, aesthetic, and safety features do not distort visibility of opening/access or fill status indicator Accommodation No sharps edges or materials Safety features do not impede free access to opening Promotes patient and user satisfaction Simple and easy to operate Any emissions from final disposal comply with emission pollution regulations Easily assembled (if required) If unassembled, components are easy to store prior to assembly Promotes one-handed disposal of sharps Special designs available for environments with specific needs e.g. laboratories, ER, pediatrics, emergency medical services, correctional facilities Mounting system durable, secure, safe and cleanable Optional lockable mounting available Mounting system allows height adjustment Design promotes task confidence System is cost effective Additional NIOSH Requirements for Sharps Containers Remain functional during entire usage until final disposal Inlet prevents spillages during closure, sealing & transport in facility Durability and puncture resistance unaffected by minor changes in temperature during storage and use. Materials resistant to chemical or liquid permeation or degredation, tearing, abrasion and laceration Closure mechanism, once activated, is resistant to manual opening Available in size able to accommodate largest sharps Has mechanism to restrict hand-entry during use, including children’s hands. Handles are sturdy Designed for simple, easy and safe disposal of sharps Available with mountings on wheels. Agree 1 Disagree 2 3 4 5 Agree Additional NIOSH Requirements (contin.) Container placement complies with regulatory, site-specific, or accreditation requirements Containers can be placed so as to be: o Accessible within room where sharp was generated o Unobstructed by furniture, equipment etc. o Easily visible and recognizable o Sufficiently illuminated Containers can be placed so as not to be: o In room corners o Backs of doors o Under or inside cabinets, or attached to inside of cabinet door o Under sinks o Above where patients or visitors sit or lie o Near light or thermostat switches, or mail boxes o Subject to traffic or equipment impact Design should minimize cross infection hazards Easy, safe placement and removal from mounting systems Mountings designed specifically for system Worker training provided before system introduced Multilingual educational materials, where appropriate Sufficient quantities of containers available for projected volumes. User instructions include: All sharps containers Assembly (where appropriate) Safety considerations Optimal storage conditions Warranty information Bilingual or multilingual material, where needed Disposal procedures and considerations Information for periodic in-service re-training, if required. Reusable sharps containers: Maintenance criteria Decontamination recommendations Container retirement considerations Score: NIOSH Requirements (possible Best = 85) 1 Disagree 2 3 4 5 6. Clinical Requirements All Sharps containers Peer-reviewed published studies confirm system’s ability to reduce sharps injuries Written evaluative research confirms high approval rating by clinical users Certified to meet Emergency Care Research Institute Tests for Sharps Containers Certified high Needle Penetration Force ≥4.5 lbf / 20N. Leakproof when dropped on lid (i.e. tested while containing 5% fluid) Colour-coded containers for Pharmaceutical sharps waste. Stable when used or stored (i.e. pass 150 Topple Test) Preassembled Intuitive and simple to use Foot-operated models available Large opening with passive safety features in patient-room containers allows safe sharps disposal while passively restricting hand entry. Needle unwinder absent Container promotes wall-space efficiency Passive safety features prevent overfilling and protrusion injuries Bracketry enables ergonomic container placement at all workstations, including walls, benches, carts, gurneys Temporary closure device enables safe closure and movement. Tamper-proof when closed for disposal Designed to facilitate vertical stacking in Utility rooms Ergonomic handle Safe, ergonomic & spatially-economic on-site storage systems. Multi-media education systems for users. Electronic summary of container locations by room & clinical unit. Reusable Containers Peer-reviewed published studies confirm system’s ability to reduce greenhouse gas emissions of sharps waste stream System allows container exchange either by healthcare facility or external contractor Clear cost benefit analysis comparing current and reusable system Testimonials confirm QA and service performance Container traceability, including client history & number of uses Continuous monitoring of container wash parameters Automated processing of all container sizes. Laboratory confirmation that washing process achieves effective reduction of vegetative pathogens Yes/ No Reusable Containers (contin.) Closure mechanism is integrally attached to container Internal transportation systems facilitating ease of transfer of full and clean containers between clinical unit and dock/Store External transportation systems facilitating ease of transfer of full and clean containers between user and processing facility After processing, the containers: o Are subjected to a multi-point QA check o Meet their original performance elements o Are aesthetically clean, i.e. free of soil and organic matter, prominent marks, scuffs or abrasions, etc. Processor: o Has written comprehensive Risk Assessment to: Assess risks Decide what precautions are needed Prevent or adequately control sharps injury and infection/illness exposure o Has Standard Operating Procedures for operating, cleaning and servicing machine, including PPE for staff & visitors o Maintains sharps injury Log o Ensures injury control measures are used and maintained o Ensures employees are informed, trained and supervised in BBP Exposure Precautions. o Has written plans and procedures to deal with accidents, incidents and emergencies Score: Clinical Requirements (maximum = 42 Yes) Yes/ No