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The Occupational Safety and Health Administration (OSHA) is requesting information and comment on engineering and work practice controls used to eliminate or minimize the risk of exposure to bloodborne pathogens due to needlesticks. Published in the Sept. 9, 1998, Federal Register, OSHA’s action may be a prelude to new regu lations or may be used to expand requirements under the 1991 bloodborne pathogens standard.1
"Percutaneous injuries [PIs] continue to be a concern in work settings where employees are exposed to bloodborne pathogens," OSHA states in the document. "The agency is considering possible actions that it can undertake to assist in addressing this issue. Consequently, OSHA is interested in strategies for reducing percutaneous injury rates that have been successfully implemented in the work environment, including work practices and, in particular, the use of devices designed to limit the risk of such injuries."
OSHA has set a Dec. 8, 1998, postmark deadline to receive information and comments based on a series of 16 questions that ask for a full description of the respondent’s facility, work force, needlestick rates, and current experiences with the use of needle safety devices. In addition to the questions, OSHA generally encourages respondents to address any aspect of PI prevention strategies they consider pertinent to the issue. For complete details on each question posed, see the full document.
The key issues are as follows:
1. What is the type, size, and employment of your facility? How many of those employees have the potential to sustain a sharps injury, and what are their job classifications?
2. Do you have a surveillance system for tracking PIs? If so, does it track PIs other than those recorded on the OSHA 200 log?
3. What is the total number of potentially contaminated PIs that have occurred in your facility in the past year and previous years?
4. What is the injury rate from potentially contaminated sharps in the past year and previous years?
5. What methods and criteria are used to evaluate the effectiveness of existing exposure controls?
6. Has any type of integrated PI prevention program been established to reduce injuries? If so, describe its structure, content, results, problems and/or successes.
7. To what extent have devices designed to reduce PIs been adopted in your facility?
8. On what basis are decisions made in your workplace concerning selection of safer medical devices? Include design and performance criteria, how PI data are used, input from device users, costs, and other factors.
9. Have safer medical devices been readily accepted and correctly used when provided?
10. What provisions are made to ensure adequate training and education in the use of safer devices and/or safer work practices?
11. How effective are safer medical devices and/or safer work practices in reducing PI rates?
12. Has use of safer devices/and or safer work practices in any way affected patient care delivery?
13. Based on observations in your workplace and your knowledge from other sources, describe any obstacles encountered relative to selection, purchase, and effective implementation of safer medical devices in the workplace, along with comments detailing successful and/or unsuccessful methods of overcoming those obstacles.
14. Provide information on costs associated with implementing safer devices and any savings resulting from their use, as well as on methods for calculating costs and savings.
15. Describe any problems associated with sharps disposal containers, as well as successful and/or unsuccessful measures undertaken to correct those problems.
16. Based on experience in your workplace and your knowledge from other sources, what are the most effective means of preventing needlesticks and other PIs? Explain the basis for your opinion and provide any supporting evidence.
[Editor’s note: According to OSHA, comments should be submitted in quadruplicate or one original (hard copy) and one diskette (5¼ or 3½ inch) in WordPerfect 5.0, 5.1, 6.0, 6.1, 7.0, 8.0, or ASCII to the Docket Officer, Docket No. H370A, Room N-2625, U.S. Department of Labor, 200 Constitution Ave. NW, Washington, DC 20210. Telephone: (202) 219-7894.
Comments of 10 pages or fewer may be transmitted by fax to (202) 219-5046, provided the original and three copies are sent to the Docket Office thereafter. Comments also may be submitted electronically through information provided on the aforementioned OSHA Internet site.]
1. Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens: Request for information. 63 Fed Reg 48,250-48,252 (Sept. 9, 1998).