Needle safety is the law: Make the transition now

Make it clear that there is not an option’

The nation’s health care facilities continue to make the landmark transition to needle safety devices as mandated by the federal Needlestick Safety and Prevention Act signed into law two years ago. Tips and insights into overcoming obstacles in this difficult process recently were offered by two experts on the issue at a special audio conference sponsored by Thomson American Health Consultants, publishers of Hospital Infection Control.

Ending years of debate and controversy about the need to implement needle safety devices, Congress stepped in and told the Occupational Safety and Health Administration (OSHA) to make it happen (effective for all states Oct. 18, 2001). As a result, OSHA amended its 1991 bloodborne pathogen standard and began requiring the routine evaluation and purchase of needle safety devices.

"This is the first time in the 31-year history of OSHA that Congress has directly intervened into the OSHA regulatory-making process," says Bruce E. Cunha, RN, MS, COHN, manager of employee health and safety at Marshfield (WI) clinic. "Since these changes were brought about by legislative action, none of the regular input or review processes were carried out."

What exactly is OSHA requiring? For the definitive answer to all aspects of that question you can go to OSHA’s actual inspection manual (CPL 2-2.69) under guidelines and regulations at your free subscriber web site at

"It gives you clear examples regarding what an inspector will be looking for," says Katherine West, BSN, MSEd, CIC, an infection control consultant with Infection Control/Emerging Concepts in Manassas, VA. The main required elements are, of course, sharps safety devices, hands-on training, and employee participation in the selection and evaluation process. "OSHA wants to see clear documentation of this entire process, and it needs to be written into your exposure control plan," she says.

Know your state status

Complicating compliance is the fact that laws may differ somewhat from state to state. As the needle safety issue rose in prominence, some states moved ahead with their own laws to protect health care workers. Some states are on "state" OSHA plans, which give them the prerogative to adopt more stringent measures then the federal requirements. At a minimum, they must require what federal OSHA requires.

"You want to really pay attention to the fact that in state-plan states, coverage [and] protection is offered to state and municipal workers, and that is not the case in federal OSHA states," West adds.

"In planning the transition to safer sharps products, it is critical to have the backing of your facility’s administration," Cunha adds. "In some facilities, a written authorization to get the project accomplished may be needed." His tips for an easier transition process include forming a steering committee made up of top personnel; not trying to implement too much at one time; and training and retraining workers. "It is important to train employees when they evaluate the product and [retrain] them when the product is introduced," he says. "The more time you spend on getting employees used to the safety device, the greater the use of the device will be."

Key members of the evaluation committee would likely include infection control, occupational health, union members, administration, risk management, emergency medical staff, and particularly, purchasing.

"Purchasing will have to understand that with this government mandate, things will not always be as they have been with group-buying programs," West says. "[Even] if they have cooperative buying agreements with various groups, those do not necessarily hold if the products under the agreement do not meet the needs of the staff or the criteria during evaluation and trial use. If what is in the purchasing agreement doesn’t cut the mustard, then we have to look outside the agreement. This can be a hard thing for them to understand. That is why it is important that they be on the committee."

Starting with the purchasing department, make a detailed list of all sharps products used in the facility, Cunha advises. Walk through supply areas and determine whether some departments are directly ordering their own equipment, he says. You may want to divide the sharps into specific categories such as IV access, IV injection, blood drawing, sharps containers, surgical blades, and hypodermic needles. While many ICPs have taken the tack of implementing safety devices immediately for high-risk exposures, starting with something simple may curry favor and buy-in from staff. "It might be relatively easy to convert to a needleless IV system," he says. "I know some places start with the hardest needles. We started with the easiest. Some of the IV cannulas on the market don’t require much of any change in technique to use. So these might be easier devices to introduce than those that actually require employees to learn a new technique. Starting with easier items might also move employees into the mindset that the changes aren’t all that difficult. You want to tackle some of the hardest items, such as sutures and surgical blades last. These are going to take the most work, and they are likely to be met with the most resistance."

Take long-term view

Cost of the devices will be a source of discussion and resistance, but OSHA fines may be just as expensive for hospitals that shirk the requirements. "You have to, first of all, make it clear that there is not an option," Cunha says. "We [have to] get the safety devices in. As safety devices come on the market — much like we saw with gloves — we’re going to see those costs drop."

On the other hand, the savings will include preventing needlesticks and their broad spectrum of medical and emotional costs. "I think that is a really important point for people to bring out to administration when they are beginning the discussion process," West says. "Costs may look inflated on the front end, but we have to look at it over the long term."

Obtain staff buy-in for the need to change by sharing the sharps injury numbers for your facility over the past one to two years, she advises. "Also [describe how] the injuries occurred. I think when you lay it out that way for staff it will clearly demonstrate the need for change."

Once a new device has been implemented, there is no hard-and-fast rule regarding when the old conventional stock should be phased out. The sooner the better is Cunha’s rule. "The longer they are around, the longer the employees will use them and not learn to use the new devices. We understand this is tough, but you’ve just got to get people understanding that change is here."

[Editor’s note: For a CD of the complete audio conference, call American Health Consultants customer service at (800) 688-2421 and ask for "Sharps Safety Compliance: How to Avoid OSHA Citations and Costly Fines" for the special rate of $199.]