Union offers checklist’ on filing OSHA complaints

Safer needle directive may spur SEIU action

The Service Employees International Union (SEIU) in Washington, DC, which represents some 650,000 health care workers, has issued a fact sheet on the recent bloodborne pathogens directive from the U.S. Occupational Safety and Health Administration, highlighting significant provisions.

The SEIU notes that enforcement of the directive will largely occur in response to complaints.

"[I]t will be left to workers and their union representatives to work closely with OSHA and file OSHA complaints against employers that refuse to evaluate and buy the best devices," the directive states. "Only after many employers are cited, and these cases are widely publicized, will health care industry practices finally begin to improve."

The SEIU also offers this checklist that could guide decisions on whether to file a complaint, with a caveat that "any no’ answers to the questions below can be grounds for an OSHA citation":

1) Is a hard copy of the Exposure Control Plan made available to a requesting employee or their representatives with 15 working days? Yes n No n

2) Does the employer review and update the Exposure Control Plan at least annually, and more frequently whenever new or modified procedures are adopted and/or whenever employee positions are revised to create new potential exposures? Yes n No n

3) Is the employer providing needleless or shielded needle IV line access products? Yes n No n

4. Is the employer using safer needles and other sharps with integrated safety features in all of the following product categories listed below:

a) Syringes (retractable or protective sheaths)? Yes n No n

b) Blood collection devices (retractable, self-blunting or sheathing)? Yes n No n

c) IV access products (retractable needle)? Yes n No n

d) Lancets (retractable)? Yes n No n

e) Blunt surgical needles where medically appropriate? Yes n No n

f) Safer scalpels? Yes n No n

5) Is the employer avoiding buying the cheapest safer devices, and is instead buying the "best" safer needles such as retractable (vs. sheathing) syringes and self-blunting (vs. sheathing) blood collection needles? Yes n No n

6) Does the employer ban the reuse of blood tube holders for blood collection, to protect workers from the dangerous practice of disassembling used needles from blood tube holders? Yes n No n

7) Has the employer provided frontline health care workers with adequate orientation and training on the use of safer devices by assuring that:

— the person conducting the training is knowledgeable? Yes n No n

— the training is interactive, allowing for questions and answers with the person conducting the training sessions? Yes n No n

— workers are trained about the location of the exposure control plan and procedures to follow if an exposure occurs? Yes n No n n