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Guidelines for Community-Based Organizations Interested in Accepting Sharps Used Outside of Health Care Settings for Safe Disposal

  • Appendix 1 - Model of Policies and Procedures
  • Appendix 2 - Regulated Medical Waste Self-Transport Registration Form to be filed with the NYSDEC
  • Appendix 3 - Model Agreement for Non-Community Based Organization (CBO) Sharps Transport and Disposal (PDF, 14 KB, 1pg.)
  • Appendix 4 - Regulated Medical Waste Tracking Form (PDF Format on the NYSDEC website)
  • Appendix 5 - Model Exposure Control Plan (ECP)

I. Purpose

This document provides guidance for community-based organizations (CBOs) interested in offering their clientele or community members who may use hypodermic needles, syringes, lancets and other "sharps" an added service of collecting used sharps at the CBO. By doing so, CBOs can play an active role, along with pharmacies and health care facilities, to help remove used syringes and other sharps from communities. Safe disposal prevents these items from ending up on streets, in parks, in schoolyards, in municipal wastewater treatment plants, in the solid waste stream or in with recyclables. Safe disposal also minimizes both sharing of syringes and accidental needlestick injuries.

The New York State Department of Health (NYSDOH) - through its Expanded Syringe Access Demonstration Program (ESAP) - and the New York State Department of Environmental Conservation (NYSDEC) seek to facilitate proper and safe disposal of hypodermic needles, syringes, lancets and other sharps used outside of health care settings in communities statewide. NYSDOH and NYSDEC staff are available to provide technical assistance to interested CBOs. Information on how to contact NYSDOH and NYSDEC staff is included in Section IV of these Guidelines.

II. CBO Role in Safe Sharps Disposal

To promote safe disposal of used hypodermic needles and syringes, lancets, and other "sharps" used outside of health care settings, CBOs can participate in any or several of the following:

  • Distribute copies of the ESAP brochure (Be Aware....Don't Share) or the ESAP "safety insert", which discusses safe disposal.
  • Make available the NYSDOH brochure, How to Safely Dispose of Household Sharps.
  • Display the NYSDOH poster, How Can You Dispose of Used Sharps Safely?
  • Participate in local efforts to educate the public about the importance of safe and proper disposal of household sharps.
  • Refer individuals to sharps disposal programs located in the community - in hospitals, nursing homes, and other settings
  • Encourage use of puncture-resistant personal sharps containers or sharps disposal by mail systems.
  • Accept hypodermic needles and syringes, lancets, and other "sharps" used by individuals outside of health care settings for safe disposal.

Any CBO in New York State interested in participating as a safe sharps collection site must:

  • Register with the NYSDOH, under ESAP, as a collection site.
  • Comply with NYSDEC regulated medical waste regulations.

CBOs may also need to comply with the federal Occupational Safety and Health Administration, U.S. Department of Labor, OSHA Directives CPL 2-2.69 - Enforcement procedures for the occupational exposure to blood borne pathogens 11/27/2001.2

Only household sharps - which include lancets, hypodermic needles and syringes used by individuals outside of health care settings - may be accepted by CBOs. Sharps generated by a licensed health care provider offering services in the home, for example, may not be accepted. In this instance, the home health care provider is responsible for the safe disposal of the sharps.  Sharps brought to a CBO for disposal must be contained in sealed, rigid, puncture-resistant, leak-proof containers. Individuals with loose sharps should be advised to place them in puncture- resistant containers, such as sharps disposal containers or bleach or laundry detergent containers. CBOs may choose to make such containers available to their clients or may refer their clients to pharmacies to purchase personal sharps containers.

Options available for CBOs interested in offering their clients who use syringes, lancets and other "sharps" an added service of collecting used sharps include:

A.  Installation of a tamper proof sharps collection "kiosk" or "drop box" for direct deposit of contained sharps by customers.

In this case, individuals can, deposit contained sharps into "kiosks" or "drop boxes".  Collection "kiosks" or "drop boxes" must be properly secured to assure that the contents, once deposited, cannot be removed except by authorized personnel. Only trained CBO staff or other appropriately trained personnel may have access to the sharps.  Collection "kiosks" or "drop boxes" must be maintained and cleaned appropriately. Sharps collected in the "kiosks" or "drop boxes" must be transported appropriately.

CBOs that locate a collection "kiosk" or "drop box" on-site may arrange with a health care facility or regulated medical waste hauler to maintain and clean the "kiosk" or "drop box" (including emergency clean-up of any spills), empty the "kiosk" or "drop box", and pick up and transport the sharps for safe disposal.  Under this scenario, the CBO would not be subject to the OSHA provisions and would not be required to develop an Exposure Control Plan.2 In this case, CBO staff would not be expected to come into contact with sharps and there would be no potential for occupational exposure. 

B. Use of CBO staff to receive contained sharps from customers for placement into a receptacle located in a secure location. 

A sharps collection system may be established under which individuals hand sharps that are already enclosed in sealed, puncture resistant containers to CBO staff for placement in a container or receptacle located in a secure location. In this instance, CBO staff will be handling the sharps - accepting them from individuals and placing them into a larger puncture resistant container. In addition, depending on the model used, CBO staff may open, clean, or empty a "kiosk", "drop box" or other collection container and may transport the collected sharps for safe disposal. 

Under this option the CBO must develop an Exposure Control Plan (see Appendix 5) and comply with any pertinent OSHA provisions.2 A "Model Policies and Procedures" is included as Appendix 1.The Exposure Control Plan must describe how the CBO will address potential worker safety issues associated with the handling and transportation of residential sharps, including assuring compliance with OSHA's standards for blood-borne pathogens.2 CBOs must assure that staff are aware of the risks associated with handling sharps and are knowledgeable about safe handling procedures. The Exposure Control Plan established must describe the following:

  • All occupations in which individuals may, under reasonable situations, be at risk for needlestick injuries while on the job.
  • Potential circumstances that may lead to needlestick injury.
  • Engineering controls to prevent needlestick exposure or injury.
  • Availability of hepatitis B prophylaxis for employees determined to be at risk for needlestick injury.
  • Record keeping for employee training and needlestick injury incidents.

A Policies and Procedures model is included as Appendix 1. A model Exposure Control Plan is included as Appendix 5.

III. Transport of Sharps for Safe Disposal

Sharps collected at a CBO must be transported to a NYSDEC-approved storage, treatment, or disposal facility. This may be accomplished by the CBO itself or through an agreement with another entity. Each of these options is described below:

Option #1: Transport by the CBO to an Approved "Storage, Treatment or Disposal Facility"

CBOs may transport less than 50 pounds of "regulated medical waste" per month to a facility authorized to accept medical waste as long as the CBO registers its intent to transport and the final destination with NYSDEC. Appendix 2 contains the Regulated Medical Waste Self-Transport Registration Form that needs to be filed with the NYSDEC.

Option #2:  Transport and Disposal by the Another Entity 

The CBO may enter into an agreement with an approved entity, either a health care facility licensed by NYSDOH under Article 28 of the NYS Public Health Law or a NYSDEC-permitted regulated medical waste hauler to pick up, store and, if necessary, assure ultimate safe disposal of sharps. The CBO and transporting entity must have a signed agreement that specifies the roles and responsibilities of each party. This agreement must be submitted to both the NYSDEC and the NYSDOH. A model Agreement for Sharps Transport and Disposal is included as Appendix 3

Regardless of the disposal option selection, a Regulated Medical Waste Tracking Form must accompany all shipments of used sharps.  The entity managing the "kiosk", "drop box" or other receptacle must maintain a copy of all tracking forms for a period of three years. A "Regulated Medical Waste Tracking Form" is included as Appendix 4.

IV. Questions Concerning These Guidelines

Questions and requests for technical assistance concerning CBO acceptance of hypodermic needles, syringes and other "sharps" used outside of health care settings for safe disposal can be directed as follows:

NYSDEC 

Division of Solid and Hazardous Materials, Bureau of Solid Waste, Reduction & Recycling, Dr. Alan Woodard, (518) 402-8693

  • NYSDEC Regulations
  • How to locate a NYSDEC-permitted Regulated Medical Waste Hauler
  • Pharmacy transport of collected "sharps"

NYSDOH

Bureau of Hospital Services, Delton Courtney, (518) 402-1004

  • Regulated medical waste
  • How to locate a NYSDOH-approved health care facility

AIDS Institute Harm Reduction Unit, (212) 417-4740

  • General information about the Expanded Syringe Access Program (ESAP)

Notes

  1. NYS Department of Environmental Conservation. 6NYCRR Parts 360 and 364. Available at: http://www.dec.ny.gov Then, type 6NYCRR Parts 360 and 364 in the Subject Index and click Search.
  2. Occupational Safety and Health Administration, U.S. Department of Labor. Directives CPL 02-02.069 - Enforcement procedures for the occupational exposure to blood borne pathogens 11/27/2001. Available on the OSHA website.