Dear Center for Phlebotomy Education:

Our collection centers will draw blood while the patient remains in their car when walking is difficult for the patient. Under these circumstances, can the used needle, with safety device activated, be taken back into the building and then placed in a sharps container? Or must the used needle be placed in a sharps and then carried back to the building?

Our response:

In its Bloodborne Pathogens Standard, OSHA states that contaminated sharps shall be discarded immediately or as soon as feasible in containers that meet the requirements set forth in Section 1910.1030(d)(4)(iii)(A)(1) (Contaminated Sharps Discarding and Containment). No exception is made for the location of the draw.

In the same section, the standard further states that containers for contaminated sharps shall 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. OSHA clarified this in 2007 in a Letter of Interpretation.

So, for phlebotomists performing curbside draws, they need to have collection supplies, including sharps containers, available at the point of use. They also need an appropriate secondary container to transport blood samples from the car into the facility. A phlebotomy tray equipped with needed supplies including an appropriate sharps disposal container would meet OSHA's requirement for the immediate disposal of used sharps, and provide an acceptable means for blood specimen transport.

 
Got a challenging phlebotomy situation or work-related question? Email us your submission at [email protected] and you just might see it as a future case study. (Names and identifiers will be removed to assure anonymity.)