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Phlebotomy Kit: Contents, Kit vs Tray and OSHA Rules

What a phlebotomy kit holds, how kit, tray and cart differ, and which contents rules come from OSHA 29 CFR 1910.1030.

Written and maintained by CASRAI Editorial Board

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General product and regulatory information for supply and safety staff. This is not medical advice and not a procedure guide.

A phlebotomy kit is a grouped set of the single-use and reusable items used at a blood draw, packed together so they travel and are restocked as one unit. In supplier listings the same idea also appears as a phlebotomy tray, venipuncture kit, blood draw tray or venipuncture tray. This guide separates those terms, then sets out the contents rules that come from a named regulation: the OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030). For full item-by-item lists, see the phlebotomy lab supply checklist and the phlebotomy cart and tray checklist; this page does not repeat them.

What a phlebotomy kit is: kit, tray and cart

Short answer: a kit is a defined set of items; a tray is the carrier that holds a set; a cart carries trays and bulk stock. The words overlap, so read a listing’s contents rather than its name.

  • Kit or pre-packed tray. Items bundled by a supplier, sometimes sold as a single-patient pack. Whether a pack is sterile or non-sterile is stated by its manufacturer on the packaging and in its labelling.
  • Reusable carry tray. A tray a facility fills from its own stock. Its contents are whatever the facility decides, within the rules below.
  • Cart. A wheeled station that holds trays, a sharps container and bulk consumables. See the phlebotomy cart guide.

The OSHA standard does not define these three words, which is why two products with the same name can hold different items.

Typical contents and the rules that attach to them

OSHA’s standard does not publish a kit item list. It sets requirements for particular items, and those requirements are the part of a kit’s contents that is not a facility choice. Quantities are set by the facility from its draw volume and restocking cycle; no standard quantity applies.

Item category Why it is in the kit Rule that applies (29 CFR 1910.1030) Notes
Gloves Hand contact with blood is anticipated (d)(3)(ix): gloves shall be worn when hand contact with blood can reasonably be anticipated, and when performing vascular access procedures (with the exceptions in (d)(3)(ix)(D)). (d)(3)(i): the employer provides PPE at no cost to the employee. Glove material and sizes are a facility decision.
Blood collection device (needle, holder or similar) Core item of the draw (c)(1)(iv): the exposure control plan must reflect changes in technology that eliminate or reduce exposure, with annual documented consideration of safer medical devices and input from frontline employees on device selection. (d)(2)(vii): contaminated needles shall not be bent, recapped or removed, except as that paragraph allows. Gauge and length: see blood draw needle size.
Sharps container Disposal at the point of use (d)(4)(iii)(A): closable, puncture resistant, leakproof on sides and bottom, and labeled or color-coded; easily accessible and located as close as is feasible to the immediate area where sharps are used. Disposal rules: sharps disposal regulations for laboratories.
Specimen container or transport bag Holds the collected sample (d)(2)(xiii): specimens go in a container that prevents leakage during collection, handling, processing, storage, transport or shipping. Container type depends on the test; the laboratory sets it.
Other consumables (tourniquet, antiseptic, gauze, tape, labels, collection tubes) Typical items in supplier-listed kits No item-specific rule in this standard. Contents vary by supplier and facility; see the supply checklist.

What varies by facility type

Because the standard regulates items and not kits, the same rules apply wherever workers are exposed to blood, while the packing list differs. A kit for a multi-site study, for example, is built around the protocol’s tubes and labels; see specimen collection kit standardization in multi-site trials. The facility’s exposure control plan, described in the exposure control plan guide, is where the choice of devices and containers is documented.

Storage, expiry and restocking

Expiry dates and storage conditions are set by each manufacturer and printed on the packaging or in the instructions for use; follow those for every item, since a kit effectively expires with its earliest-dated part. Because sharps containers must be easily accessible and close to where sharps are used, they are restocked and replaced as part of the same routine as the rest of the kit rather than kept in a remote store.

Questions a facility can put to a kit supplier

These questions follow from the rules above and are an editorial aid, not a regulatory checklist:

  • Does the contents list name the blood collection device, so the facility can compare it with its annual safer-device review?
  • Does the kit include a sharps container, and if so does the manufacturer describe it as puncture resistant, leakproof and labeled?
  • Are gloves included, and in which sizes, given that the employer must supply PPE at no cost to employees?
  • Is the kit sold sterile or non-sterile, and what expiry date is printed on it?

Standards and rules that apply

  • OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030, checked 2026-11-04. Paragraphs cited above: (c)(1)(iv), (d)(2)(vii), (d)(2)(xiii), (d)(3), (d)(4)(iii).
  • WHO, WHO guidelines on drawing blood: best practices in phlebotomy, published 6 January 2010, covering the recommended steps for safe phlebotomy for blood taken for laboratory testing or donation.

FAQ

What is in a phlebotomy kit?

There is no universal list. Supplier kits typically group the collection device, gloves, skin-prep and dressing items and collection tubes, and a facility adds a sharps container and specimen packaging. OSHA’s standard sets rules for gloves, sharps containers, specimen containers and safer devices.

What is the difference between a phlebotomy tray and a phlebotomy kit?

A tray carries items; a kit is the set of items. A pre-packed tray is a kit, and a reusable tray becomes a kit when the facility fills it.

What is a venipuncture kit or venipuncture tray?

The same product category under another name. Compare contents lists, not names.

What is a blood draw tray?

A tray holding the items for a blood draw; it may be sold pre-packed or assembled by the facility.

Must a kit contain a sharps container?

The standard requires that contaminated sharps be discarded in compliant containers located as close as feasible to where sharps are used. It does not say the container must be inside the kit.

What is on a phlebotomy supplies list?

Start with the phlebotomy lab supply checklist, then check each category against the rules above.

Sources

  • OSHA, Bloodborne Pathogens, 29 CFR 1910.1030: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030 (checked 2026-11-04)
  • OSHA, Bloodborne Pathogens and Needlestick Prevention standards page: https://www.osha.gov/bloodborne-pathogens/standards (checked 2026-11-04)
  • WHO, Guidelines on drawing blood: best practices in phlebotomy (2010): https://www.who.int/publications/i/item/9789241599221 (checked 2026-11-04)

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