5 steps to compliance with OSHA regulations

What can you, as a manager, do to help ensure members of your staff are complying with sharps safety regulations?

“I believe the key is education and training,” says Stephen Morrison, BSEH, health compliance officer with the Tennessee Occupational Safety and Health Administration (TOSHA) in Kingsport. “They must be made aware of the consequences of noncompliance such as health risks to themselves, their patients, and their staff, and monetary fines that can be thousands of dollars.”

Education is key, agrees Mary Ogg, MSN, RN, CNOR, perioperative nursing specialist at the Association of perioperative Registered Nurses in Denver. “Many healthcare providers are unaware of the risks of hepatitis C or HIV from a sharps injury,” Ogg says. “Seroconversion to hepatitis C or HIV has career- and life-altering consequences.”

Share personal stories from your staff (being cognizant of potential violations of privacy laws) or published accounts, she advises. Karen Daley, president of the American Nurses Association, has shared her needlestick injury story and how it changed her career path from clinical practice as an emergency department nurse. (To read Daley’s story, go to http://bit.ly/ZWtls1. Also see one surgeon’s story in “Provider-to-patient transmission of HBV raises issues about staff — CDC updates guidelines for facilities,” Same-Day Surgery, April 2013, p. 41.) “Ask your staff how they felt as they awaited results of lab tests to confirm whether they have been exposed,” Ogg says.

The hope is that education equals a change in behavior, “but unfortunately this is not always reality,” she says, “An OSHA fine is a great motivator to change.”

Providers may request an OSHA consultation, which is free and doesn’t result in monetary penalties, according to Morrison. Consider these other suggestions:

• Obtain input from your staff on products.

Under the Needlestick Safety and Prevention Act, front-line workers who use sharps safety products are required to conduct an evaluation. “Conduct the yearly evaluation, and select the one that has the best user feedback,” Ogg advises. “Acceptance is more likely if the user has input into the decision of what device to use rather than a device showing up one day and being told that they have to use it.”

Don’t pass hand to hand.

Where possible, have a safe zone where you pass instruments, says Teo Forcht Dagi, MD, DMedSc, FAANS, FACS, SAAANS, FCCM, a neurosurgeon and chair of the American College of Surgeons Committee on Perioperative Care, which created the college’s Statement on Sharps Safety. Forcht Dagi also is a visiting professor at Harvard Medical School in Boston and professor at Queens University Belfast, Northern Ireland, UK.

Put sharps in an intermediary tray so there is reduced risk of injury by contact, he says. However, the nature of some procedures makes a sharps safety zone difficult, Forcht Dagi acknowledges. He points to ophthalmology and neurosurgery procedures in which you have micro-techniques using tiny needles. Even in those cases, surgeons and staff can develop systems, such as a magnetic one, to use. “But the principle is the same: The principle is to try to avoid as much as you can passing something that is sharp from one hand to another,” Forcht Daggi says.

Also, use blunt needles, when possible, for closure, he says.

Have staff double glove.

Ogg says, “Double gloving is the easiest sharps injury prevention measure to implement.” This one step can reduced sharps injuries by as much as 87%, she says.

“Resistance to arguments that double gloving is uncomfortable or reduced tactility can be overcome by inviting your glove vendor in to help personnel find the proper fit,” Ogg says.

Don’t assume that the only way to double glove is to wear one size larger glove over the inner glove, she says. “Try different combinations and after a week or two, personnel become used to the slightly different feel, like wearing a seat belt,” Ogg says.

Record all needlesticks, but not all splashes.

“All sharps injuries should be reported,” Ogg says. “One can never be certain by outward appearance which patient may be infected with HIV or Hepatitis C.”

Any sharps injury that involves a needle or object that was contaminated with a patient’s blood or other potentially infectious material must be reported on a sharps log and the OSHA 300 log, even if the patient does not have a bloodborne pathogen. The OSHA 300 log can serve as the sharps injury log if the sharps injuries can be segregated easily from other injuries. There are privacy cases, so the employee’s name should not appear on the log.

A needlestick is considered to be a puncture (injury) unless an infection develops. If an employee develops an infection and receives medical treatment, the log should be updated. Splashes of blood and body fluid do not need to be reported unless the employee develops an infection and requires medical treatment.