AHA: Use needle devices to comply with OSHA

OSHA action effectively requires’ sharps safety

The Occupational Safety and Health Admini stration’s recently revised compliance directive for its bloodborne pathogen standard "effectively requires hospitals to use [needle] safety devices," the American Hospital Association in Washington, DC, is advising. In a regulatory advisory issued to hospitals by AHA executive vice president Rick Pollack, the association notes that OSHA has consistently required hospitals to use engineering controls and work practices as the primary means of eliminating or minimizing employee exposures.

"In the directive, OSHA defines engineering controls as controls that isolate or remove bloodborne pathogen hazards from the workplace," Pollack notes. "OSHA uses safety devices such as needleless devices, shielded needle devices, blunt needles, and plastic capillary tubes as examples of engineering controls. OSHA has explicitly included safety devices in its definition of engineering controls. This effectively requires hospitals to use safety devices to meet the bloodborne pathogen standard."

In recently revising its compliance for inspectors enforcing the 1991 bloodborne pathogen standard, OSHA mandated that needle safety device evaluation efforts must be documented at least annually in the exposure control plan.1 If a combination of engineering controls (i.e., shielded needle devices) and work practice controls (i.e., eliminating hand-to-hand instrument passing in the operating room) does not eliminate or minimize exposures, the employer shall be cited, OSHA determined.

Still, some infection control professionals have recommended against blindly purchasing all manner of devices to comply with the changes. (See Hospital Infection Control, January 2000, pp. 1-6.) Similarly, the AHA reminds that "rather than require the use of specific devices, OSHA’s directive allows hospitals to adopt safety devices based on their own evaluation of the needs of their patients and employees." However, the AHA emphasizes that while the directive is "flexible, [it] requires hospitals to take action." To make sure hospitals are in compliance with OSHA’s directive, the AHA recommends the following:

• Review your exposure control plan to ensure it meets all the requirements of OSHA’s directive. Make sure there is collaboration among infection control, risk management, safety staff, clinicians, occupational health staff, and other workers to implement the bloodborne pathogen regulation in your hospital.

• Record all actions taken to comply with OSHA’s directive including any future plans. Be sure to document all training and education of workers in the use of safety devices.

• Begin implementing a sharps injury prevention program if you have not already done so.

• Document steps taken to reduce injuries through the use of safety devices and work practices. Any difficulties encountered in using safety devices also should be documented.

• Document the circumstances surrounding all exposure incidents.

• In states that have OSHA-equivalent standards, contact your state enforcement agency to make sure you are also in compliance with their regulations.

[Editor’s note: For more information, visit AHA’s Web site at www.aha.org. The OSHA directive can be accessed on the Internet at the OSHA home page at www.osha.gov. Copies also can be obtained from the agency’s publications office by calling (202) 693-1888.]

Reference

1. Occupational Safety and Health Administration. 29 CFR 1910.1030. "Occupational Exposure to Bloodborne Pathogens." OSHA instruction CPL 2.103. Field inspection reference manual. Nov. 5, 1999.