OSHA questions address sharps injury prevention

Commentors urged to describe strategies

The U.S. Occupational Safety and Health Administration’s request for information on engineering and work practice controls that successfully eliminate or minimize contaminated sharps injuries incurred by health care workers on the job includes 16 key questions to provide a basis for response, but commentors are encouraged to address any aspects of percutaneous injury (PI) prevention strategies they consider pertinent.

For complete details on each question posed, see the full document.1 The key issues are:

1. What is the type, size, and employment of your facility? How many of those employees have the potential to sustain a sharps injury, and what are their job classifications?

2. Do you have a surveillance system for tracking PIs? If so, does it track PIs other than those recorded on the OSHA 200 log?

3. What is the total number of potentially contaminated PIs that have occurred in your facility in the past year and previous years?

4. What is the injury rate from potentially contaminated sharps in the past year and previous years?

5. What methods and criteria are used to evaluate the effectiveness of existing exposure controls?

6. Has any type of integrated PI prevention program been established to reduce injuries? If so, describe structure, content, results, problems and/or successes.

7. To what extent have devices designed to reduce PIs been adopted in your facility?

8. On what basis are decisions made in your workplace concerning selection of safer medical devices? Include design and performance criteria, how PI data are used, input from device users, costs, and other factors.

9. Have safer medical devices been readily accepted and correctly used when provided?

10. What provisions are made to ensure adequate training and education in the use of safer devices and/or safer work practices?

11. How effective are safer medical devices and/or safer work practices in reducing PI rates?

12. Has use of safer devices and/or safer work practices in any way affected patient care delivery?

13. Based on observations in your workplace and your knowledge from other sources, describe any obstacles encountered relative to selection, purchase, and effective implementation of safer medical devices in the workplace, along with comments detailing successful and/or unsuccessful methods of overcoming those obstacles.

14. Provide information on costs associated with implementing safer devices and any savings resulting from their use, as well as on methods for calculating costs and savings.

15. Describe any problems associated with sharps disposal containers, as well as successful and/or unsuccessful measures undertaken to correct those problems.

16. Based on experience in your workplace and your knowledge from other sources, what are the most effective means of preventing needlesticks and other PIs? Explain the basis for your opinion and provide any supporting evidence.


1. Department of Labor, Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens: Request for information. 63 Fed Reg 48,250-48,252 (Sept. 9, 1998).