OSHA’s needle safety basics

The major components of the needlestick safety law and revised bloodborne pathogens standards have been widely publicized. Here are the basics the federal Occupational Safety and Health Administration (OSHA) says are required to meet the new rules:

Exposure control plan

An annual review and update of the Exposure Control Plan should reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens. The employer must:

• take into account innovations in medical procedure and technological developments that reduce the risk of exposure (e.g., newly available medical devices designed to reduce needlesticks);

• document consideration and use of appropriate, commercially available, and effective safer devices (e.g., describe the devices identified as candidates for use, the method(s) used to evaluate those devices, and justification for the eventual selection).

No one medical device is considered appropriate or effective for all circumstances. Employers must select devices that, based on reasonable judgment:

• will not jeopardize patient or employee safety or be medically inadvisable;

• will make an exposure incident involving a contaminated sharp less likely to occur.

Employee input

Employers must solicit input from nonmanagerial employees responsible for direct patient care regarding the identification, evaluation, and selection of effective engineering controls, including safer medical devices. Employees selected should represent the range of exposure situations encountered in the workplace, such as those in geriatric, pediatric, or nuclear medicine, and others involved in direct care of patients. OSHA will check for compliance with this provision during inspections by questioning a representative number of employees to determine if and how their input was requested. Employers are required to document, in the Exposure Control Plan, how they received input from employees. This obligation can be met by:

• listing the employees involved and describing the process by which input was requested;

• presenting other documentation, including references to the minutes of meetings, copies of documents used to request employee participation, or records of responses received from employees.


Employers who have employees who are occupationally exposed to blood or other potentially infectious materials, and who are required to maintain a log of occupational injuries and illnesses under existing recordkeeping rules, must also maintain a sharps injury log. That log will be maintained in a manner that protects the privacy of employees. At a minimum, the log will contain the following:

• type and brand of device involved in the incident;

• location of incident (e.g., department or work area);

• description of the incident

The sharps injury log may include additional information as long as an employee’s privacy is protected. The format of the log can be determined by the employer.

Modification of definitions

The revision to the bloodborne pathogens standard includes modification of definitions relating to engineering controls. Two terms have been added to the standard, while the description of an existing term has been amended:

• Engineering controls include all control measures that isolate or remove a hazard from the workplace, such as sharps disposal containers and self-sheathing needles. The original bloodborne pathogens standard was not specific regarding the applicability of various engineering controls (other than the above examples) in the health care setting. The revision now specifies that "safer medical devices, such as sharps with engineered sharps injury protections and needleless systems" constitute an effective engineering control, and must be used where feasible.

• Sharps with engineered sharps injury protections is a new term, which includes non-needle sharps or needle devices containing built-in safety features that are used for collecting fluids or administering medications or other fluids, or other procedures involving the risk of sharps injury. This description covers a broad array of devices, including:

1. syringes with a sliding sheath that shields the attached needle after use;

2. needles that retract into a syringe after use;

3. shielded or retracting catheter;

4. intravenous medication (IV) delivery systems that use a catheter port with a needle housed in a protective covering.

• Needleless systems is a new term defined as devices which provide an alternative to needles for various procedures to reduce the risk of injury involving contaminated sharps. Examples include:

1. IV medication systems that administer medication or fluids through a catheter port using non-needle connections;

2. jet injection systems that deliver liquid medication beneath the skin or through a muscle.