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Advice on complying with OSHA regs
Complying with needle safety regulations remains a challenge. The bloodborne patho-gens standard is the most frequently cited in Occupational Safety and Health Administration (OSHA) inspections of hospitals. Here are some frequent questions and answers about needle safety compliance provided by the Safety Institute of Premier Inc., an alliance of 1,700 nonprofit hospitals and health systems based in Oak Brook, IL. More information is available on the Premier web site at www.premierinc.com/safety.
If there is a safety device available for a particular procedure, does it have to be used?
If there are safety devices available for a particular procedure, they should be evaluated by frontline workers and one selected for use to reduce risks. The only exception to the use of a safety device, when available, is if the device(s) interferes with a clinical procedure and cannot be used without compromising the procedure or increasing the risk to the patient. In this case, the specific reason for not selecting and using the device needs to be documented in the exposure control plan. As part of the annual review, there should be an evaluation of any other newer devices that might be available that might not interfere with the specific procedure. This review, and the results of the evaluation should be documented; that is, either the adoption of device, or an explanation of why the device (s) interferes with a specific clinical procedure and/or increases risk to the patient.
Can cost be a consideration in the process of selection of a safety device and still meet the intent of OSHA?
Cost certainly is an important
consideration as is the cost-effectiveness in choosing a safety device. However,
it cannot be the only consideration. The most important consideration, according
to OSHA, is that frontline workers are involved in choosing the device, as opposed
to the employer selecting
a device just because it is the lowest in cost. There may be opportunities for cost-effective devices under a group purchasing contract; however, the devices chosen by the frontline worker must be implemented whether or not they are covered by
a group purchasing contract.
What is the definition of "frontline worker"?
Frontline workers are those who actually use the safety devices and could be staff nurses or charge nurses, for example, not management staff who do not use these devices.
Are employers responsible for providing safety devices for contract workers?
Yes, and the employer must provide safety devices to all employees at the work site if they are at risk of exposure to contaminated sharps, even if they are employed by another company in a contractual arrangement. For example, contract or per diem workers in a hospital are employees of the contracting agency; however, they still must be provided with safety devices, personal protective apparel, and training for compliance with all the requirements of the bloodborne pathogen standard. In some instances, some of the requirements are managed or paid for by the contracting agency and not the hospital, such as hepatitis B vaccination.
However, both employers (hospital and contracting agency) are responsible for making sure that all aspects of the OSHA standard are enforced by one of the employers, and this must be clearly documented in the contract.
Please clarify the need
for continual (annual) evaluation of new devices. If the injury rate
has been reduced and there are no reports of employee dissatisfaction, what is our obligation to review/consider a different device?
OSHA cannot tell an organization exactly what it needs to do in an annual review, except the intent of the review is to make sure that the devices being used remain appropriate, control the hazard and reduce risks to workers. The type of review can be determined by the employer and outlined in the exposure control plan. The intent is that you would not choose a device and keep using it year after year despite employee complaints and documented ongoing problems with the device. Nor does it mean you evaluate every device on the market every year. Rather, you would conduct an annual review of your program that would include a review of your devices. For example, your exposure control plan could outline which factors or data you would review/consider in your annual review. The precise type of annual review (and what data will be reviewed and by whom) and what devices are evaluated, if necessary, should be outlined in your plan.
In some small facilities or departments, where sharps injuries are rare, there might not be a need for a formal meeting, but rather the exposure control plan would outline an ongoing assessment and review of any injuries or exposures to determine if a change in a device or procedure is necessary.
The annual review could be as simple as a review of data and discussion at a safety or infection control-related meeting, with documentation in minutes. It might include documentation, for example, of your sharps injury data and mention of any considerations in the annual review (e.g., feedback from staff on acceptance of current device, etc.) such as:
• If injuries are identified, they need to be assessed to determine if the injury is from the device or perhaps some other issue such as overfilled disposal containers that needs to be addressed.
• If no injuries have occurred with a particular device or injury rates are reduced, it may be determined that a review of a new device is not needed.
If there is an increase in injuries from a specific device and all the injuries occur during activation of the safety mechanism, it might indicate the need to evaluate a different device.
It is important to evaluate the nature and circumstances of sharps-related injuries that occur and not attempt to calculate injury rates to compare safety devices that will rarely be statistically significant. Rather, you should look at trends and nature and circumstances of specific injuries to glean important information.
This is a performance-oriented standard, not a "specification standard." As such, each work site needs to develop and modify, if needed, their exposure control plan based on their work site data. The plan will include information on how their program is managed, including the annual review, and method for selection of devices with frontline worker input. This plan will vary with each facility and depend on the types of risks, review of institutional-based injury data, types of procedures performed, patient populations, and other considerations. All device selection and evaluation will be done with frontline worker input.