That's a judgement call on your part.  Technically, non-biologically 
contaminated pipette tips can be considered "RCRA Empty" - but if you 
believe a sufficient risk exists to cause some kind of puncture/injection 
wound to a worker who's taking out lab waste, then by all means create a 
standard operating procedure that eliminates the risk.  And state it in 
your Chemical Hygiene Plan.  When OSHA investigates an accident, they look 
for a specific violation (e.g. equipment lacking a belt guard), and if 
there's no specific violation on the books, they go by the General Duty 
Clause (i.e. you should have seen that one coming!).  Next, they try to 
figure out if the accident occurred as a result of bad management or if 
the worker ignored the rules, and why.  
In Los Angeles, we put the plastic pipette tips in a sharps container.     
 

Eric Clark, MS, CCHO, CHMM 
Safety Officer Los Angeles County Public Health Lab

>>> Steven Funck  4/6/2009 9:33 AM >>>
Does anyone know whether there is specific guidance concerning disposable
pipets which are not biologically contaminated. Must they be disposed of 
as
"sharps"  or can they be placed in normal trash?

Steven S. Funck
Messiah College
Natural Sciences Laboratory Programs Manager
Box 3049
1 College Ave
Grantham, PA 17027
717-796-1800 ext. 2079

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