OSHA inspectors look for device review, worker input

Key provisions from the inspection manual

The following provisions are some of the key instructions to Occupational Safety and Health Administration inspectors enforcing requirements for needle safety devices:1

Review the facility’s written exposure control plan. While the plan may be part of a larger document, such as one addressing all health and safety hazards in the workplace, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document that states the overall policy goals and references the elements of existing separate policies that comprise the plan.

Determine whether the plan is reviewed annually and updated to reflect significant modifications in tasks or procedures that may result in occupational exposure. This includes, but is not limited to, newly available medical devices designed to reduce the risk of percutaneous exposure to bloodborne pathogens. A periodic review ensures that the exposure control plan remains current with the latest information and scientific knowledge pertaining to bloodborne pathogens.

Review the sharps log to identify problem areas and/or ineffective devices that may need replacement. The exposure control plan must document consideration and implementation of appropriate commercially available and effective engineering controls designed to eliminate or minimize exposure.

The employer must solicit input from nonmanagerial employees responsible for direct patient care in the identification, selection, and evaluation of effective engineering and work practice controls and document the process in the exposure control plan.

Methods for soliciting employee input may include joint labor-management safety committees; involvement in informal problem-solving groups; participation in safety meetings and audits, employee surveys, work site inspections, or exposure incident investigations; using a suggestion box or other effective methods for obtaining written employee comments; and participation in the evaluation of devices through pilot testing.

Determine how the devices used in the facility were selected and review the employers’ documentation of their employees’ input. Many departments require different features in a safer device and have different concerns for both employee and patient safety. Employees in various departments and situations should be interviewed to determine the extent to which the employer solicited employee input. The fact that some employees have not provided input does not automatically mean the employer has not solicited input, but should prompt the compliance officer to thoroughly investigate whether input was solicited.

Safer medical devices are generally of two types: needleless systems (e.g., needleless IV connectors) and sharps with engineered sharps injury protection (e.g., self-sheathing needles on syringes). Substitution methods such as the use of plastic (instead of glass) capillary tubes also are available. Ideally, the most effective way of removing the hazard of a contaminated needle is to eliminate the needle completely by converting to needleless systems. When this is not possible, removal of the hazard as soon as possible after contamination is required. This is best accomplished by using a sharp with engineered sharps injury protection, which shields the sharp from exposure as soon as it is withdrawn from the patient. No one medical device is appropriate in all circumstances of use. Employers must implement the safer medical devices that are appropriate, commercially available, and effective.


1. Occupational Safety and Health Administration. Instruction CPL 2-2.69: Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens. Standard Number: 1910.1030. Washington, DC; Nov. 27, 2001.