COMPLIANCE DIRECTIVE FOR
The compliance directive guides OSHA's safety and health inspection officers in enforcing the standard that covers occupational exposure to blood and other potentially infectious materials, and ensures consistent inspection procedures are followed.
The directive implements changes made to the standard that focus on the requirement that employers select safer needle devices as they become available and involve employees in identifying and choosing those devices. The standard now also requires most employers to maintain a log of injuries from contaminated sharps.
The directive highlights the major new requirements of the standard including: (1) evaluation and implementation of safer needle devices as part of the re-evaluation of appropriate engineering controls during an employer's annual exposure control plan; (2) documentation of the involvement of non-managerial, frontline employees in choosing safer devices; and (3) establishment and maintenance of a sharps injury log for recording injuries from contaminated sharps.
Compliance officers are reminded that no one safer medical device is appropriate for all situations; employers must consider and implement devices that are appropriate, commercially available and effective. The directive also includes detailed instructions on inspections of multi-employer worksites, including employment agencies, personnel services, home health services, physicians and health care professionals in independent practices, and independent contractors.
Also included in the directive are engineering
control evaluation forms, a web site resource list, a model exposure
control plan which incorporates the most current guidelines from
the Centers for Disease Control regarding management of occupational
exposure to the hepatitis B and C viruses, and the HIV virus.
April 18, 2001 Revision to OSHA's Bloodborne
The standard sets forth requirements for employers with workers exposed to blood or other potentially infectious materials. In order to reduce or eliminate the hazards of occupational exposure, an employer must implement an exposure control plan for the worksite with details on employee protection measures. The plan must also describe how an employer will use a combination of engineering and work practice controls, ensure the use of personal protective clothing and equipment, provide training , medical surveillance, hepatitis B vaccinations, and signs and labels, among other provisions. Engineering controls are the primary means of eliminating or minimizing employee exposure and include the use of safer medical devices, such as needleless devices, shielded needle devices, and plastic capillary tubes.
Nearly 10 years have passed since the bloodborne pathogens standard was published. Since then, many different medical devices have been developed to reduce the risk of Needle Sticks and other sharps injuries. These devices replace sharps with non-needle devices or incorporate safety features designed to reduce injury. Despite these advances in technology, Needle Sticks and other sharps injuries continue to be of concern due to the high frequency of their occurrence and the severity of the health effects.
The Centers for Disease Control and Prevention estimate that healthcare workers sustain nearly 600,000 percutaneous injuries annually involving contaminated sharps. In response to both the continued concern over such exposures and the technological developments which can increase employee protection, Congress passed the Needle Stick Safety and Prevention Act directing OSHA to revise the bloodborne pathogens standard to establish in greater detail requirements that employers identify and make use of effective and safer medical devices. That revision was published on Jan. 18, 2001, and became effective April 18, 2001.
The revision does, however, specify in greater detail the engineering controls, such as safer medical devices, which must be used to reduce or eliminate worker exposure.
Exposure Control Plan
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 Needle Sticks); and 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; and
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.
Documentation of employee input
Listing the employees involved and describing
the process by which input was requested; or
the type and brand of device involved in the incident; location of the incident (e.g., department or work area); anddescription 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
Sharps with Engineered Sharps Injury
Syringes with a sliding sheath that shields
the attached needle after use;
IV medication systems which administer
medication or fluids through a catheter port using non-needle