Still Stuck on Needle Safety
New OSHA directive clarifies steps for reducing needlestick injuries.

Edition: February 2002 - Vol 10 Number 02
Article#: 1154
Author: Laura Thill

The heavy focus on needle safety issues in recent years has done much to raise health practitioners' concerns about the risk of occupational exposure to bloodborne pathogens. But the safety battle is not yet won.


In another step toward ensuring safety in physician offices, labs, hospitals and other health facilities, the Occupational Safety and Health Administration (OSHA) issued a new compliance directive last November enforcing the January, 2001, revised bloodborne pathogens standard. The directive looks at some new requirements of the standard, such as:
--Evaluating and implementing safer needle devices as an integral part of the re-evaluation of proper engineering controls during an employer's annual exposure control plan (procedure for assessing the details of occupational exposures.
--Documenting the involvement of non-managerial employees in the selection of safer devices
--Establishing and maintaining a sharps injury log for recording injuries from contaminated sharps.


Sharps with injury protection devices are defined in the directive as ''a non-needle sharp or needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident.'' There is no medical device appropriate for all situations, according to OSHA. It is up to employers to evaluate and select devices that are effective and available.


The directive also provides instructions for inspecting multi-employer office and work sites, including physician practices. In addition, it offers engineering control evaluation forms, a website resource list, and a model exposure plan with up-to-date guidelines from the Centers for Disease Control and Prevention on managing occupational exposure to hepatitis B, hepatitis C and HIV virus.

Highlights of the Bloodborne Pathogen Standard
Exposure Control Plan

Employers are required by the bloodborne pathogen standard to establish an exposure control plan whereby they identify duties, tasks and procedures during which occupational exposure may occur. The exposure control plan is considered key to the standard since it forces employers to identify which workers will receive training, protective equipment, vaccinations or other forms of protection.


Employers are required to review and update their exposure control plan annually- or whenever necessary- to account for new or revised tasks, procedures or positions with exposure risks.


Engineering Controls and Work Practices
OSHA's standard requires employers to use engineering and work practice controls designed to eliminate occupational exposure or reduce it as much as possible. Some physicians may not be aware that needles that will not become contaminated during use, such as those used to extract medication from vials, need not incorporate engineering controls, according to the standard. Injection needles, however, must conform to engineering controls.


Engineering controls are mandatory if they can limit employee exposure through the removal, elimination or isolation of a hazard. The most effective solution for limiting exposure incidents is to employ needleless systems, notes OSHA. Because this is not always possible, OSHA recommends using a sharp with engineered sharps injury protection, designed to shield the sharps from exposure upon withdrawal from the patient.


Safety Features for Injuries
While the FDA is responsible for clearing medical devices for marketing, this alone cannot always ensure the efficiency of a device for a particular job. It is up to the employer to further evaluate design features of all devices used. The FDA has published a list of design features considered crucial in preventing percutaneous injuries (FDA Safety Alert, April 16, 1992, and Draft Supplementary Guidance on the Content of Premarket Notification 510 (K) Submissions for Medical Devices with Sharps Injury Prevention Features, March 1995.). The design features include the following:
--A barrier is provided between the hands and the needle after use. The worker's hands should be permitted always to remain behind the needle.
--The safety feature should be effective prior to using the device and after disposal to protect users and trash handlers.
--The safety feature should require little or no training to implement.


OSHA's standard requires employers to examine, repair or replace engineering controls as frequently as necessary to ensure continuous worker protection.


Removing or Recapping Needles
As a rule, a practitioner rarely needs to remove a needle from a used blood-drawing/phlebotomy device. Generally, used needles are immediately discarded, un-recapped, into accessible sharps containers. When recapping, bending or removing needles is necessary, however, the standard requires the following:
--If recapping is absolutely necessary, it must be performed using a mechanical device or foreceps rather than using a two-handed approach.
--When necessary, the one-hand scoop method (i.e. the hand holding the sharp is used to scoop up the cap from a flat surface) for recapping is acceptable.
--When an employer finds no alternative to bending, recapping or removing contaminated needles, he or she must include written justification, supported by evidence, in the exposure control plan.




For more information on OSHA's compliance directive, visit:
www.osha-slc.gov/OshDoc/Directive_data/CPL_2-2_69.html.







Preventing Needlestick Injuries
Nearly 800,000 needlestick injuries occur annually, according to the Occupational Safety and Health Administration (OSHA). About two percent, or 16,000, of these are estimated to be contaminated with HIV. Needlestick injuries are responsible for as many as 80 percent of accidental exposures to blood.


These injuries are most likely to happen during the disposal of needles, collection and disposal of materials used during patient care procedures, or during injections or blood withdrawal. Used needles discarded in linens or trash also pose a hazard to workers who handle these items.


OSHA has identified over 20 pathogens that have been transmitted from needlesticks- the most serious being hepatitis C, hepatitis B and HIV. While it is true that needles can penetrate most protective apparel, the majority of needlestick injuries actually result from using unsafe needle devices rather than carelessness on the worker's part.


Those needles most apt to cause injury are:
-Hypodermic needles.
-Blood collection needles.
-Suture needles.
-Needles used in IV delivery systems.


Available needle safety features include:
-Passive safety features. These work before, during and after use and require no activation.
-Active devices. The safety mechanism must be activated by the worker.
-Integrated safety design. This system tends to be the most preferred since the safety feature is built into the device and cannot be removed.
-Accessory safety device. This safety feature is external to the device. It tends to be less favorable among practitioners since it must be affixed to the needle device by the worker.


Physicians and their staff can work together toward protection from needlestick injury by evaluating devices and relying on those considered most effective and appropriate for the particular work environment. Also:
-Avoid recapping.
-Plan for safe handling and disposal of needles prior to using them.
-Dispose of used needles immediately in appropriate sharps disposal containers.
-Report all needlestick and sharps-related injuries.
-Note and rectify any hazards observed.
-Participate in safety training programs.
-Get a hepatitis B vaccine.