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Hundreds of thousands more to record in 2002
Long undercounted needlestick reports are expected to begin skyrocketing next year in the nation’s health care settings under new data-keeping requirements by the Occupational Safety and Health Administration (OSHA), Hospital Infection Control has learned.
Currently, needlesticks are only reportable on OSHA 200 logs if they require medical treatment beyond first aid, lead to work restrictions, lost workdays, or result in seroconversion, an OSHA official tells HIC.
More inclusive definition
The changes are expected to result in an increase in needlestick reporting because OSHA has redefined the injury to be more inclusive. Under the new record-keeping requirements, "any needlestick injury or cut from a sharp object that is contaminated with another person’s blood or other infectious material" must be recorded.
"We expect that this [change] will add another half million cases to the statistics," says the official, who declined to speak for attribution. OSHA officials were not speaking on the record as this issue went to press because the agency was awaiting the appointment of a new administrator.
Updating requirements that have been in place since 1971, OSHA revised its record-keeping rule to improve the tracking and recording of workplace injuries and illnesses.
Published in the Jan. 19, 2001, Federal Register, the final rule becomes effective on Jan. 1, 2002.1 OSHA published the rule early to give employers ample time to learn the new requirements and to revise computer systems that may be used for record keeping.
A key change for infection control professionals in the record-keeping requirements is that needlesticks will be recorded on the new OSHA 300 form next year. ( See form, p. 38 .) There is also a new 300A form for reporting a summary of work-related injuries and illnesses and a form 301 for detailing injury or illness incidents. ( See copies of forms, inserted in this issue.) While ICPs may want to begin familiarizing themselves with the new system, OSHA advises that reports continue to be made on the current OSHA 200 form until the new regulations take effect.
True toll may now be known
Though the annual number of needlesticks has been estimated as high as 800,000, the most recent estimates by the Centers for Disease Control and Prevention are that some 400,000 sharps injuries occur annually. Many of those are either not reported by the injured worker or not recorded on the current OSHA 200 logs. For example, OSHA currently gets reports of only about 80,000 needlesticks a year.
"It’s not that the injuries will go up; it’s that the numbers will be more accurate," says Katherine West, MSEd, CIC, a consultant with Infection Control/Emerging Concepts in Manassas, VA. "Right now, if the injury does not require more than first aid — and blood testing is not considered more than first aid — it does not go on the OSHA 200 form. So that’s why the numbers will go up. We are going to have more data, and they are going to be data that are useful."
While more reports can be expected to be documented by institutions, there remains the historic problem of health care workers not reporting needlesticks for reasons that vary from lack of time to fear of reprisal. But the availability of post-exposure treatment options for HIV and the increasing awareness of hepatitis C may be providing more incentives to report than in the past.
"I think the reporting on exposures has gotten better because people want to ensure that they are going to get workers’ comp if there is some negative outcome," West says. "People are scared of hepatitis C and HIV."
As reporting improves, the new OSHA data could prove an invaluable national baseline reading as more new needle safety devices are implemented in the next few years, she adds. "Numbers, which are first going to look inflated, should go down over time."
The revised recording-keeping rule includes a provision for recording needlestick and sharps injuries that is consistent with OSHA’s recent revision of its bloodborne pathogens standard.2 Those changes become enforceable April 18, 2001. As mandated by the Needlestick Safety and Prevention Act, OSHA has revised the bloodborne pathogens standard to require employers to consider safer needle devices as they become available by updating their exposure control plans annually and involving frontline workers in choosing devices.
In an overlap that might be confusing, the new OSHA bloodborne pathogen standards also call for keeping a needlestick log. Though the record-keeping changes will not become effective until next year, OSHA is aware that ICPs and occupational health nurses may want to combine the record-keeping and bloodborne logs for ease of data keeping.
The key difference is that the bloodborne pathogen standard revisions require ICPs to record the type and brand of device causing the needlestick in the required sharps log. So if clinicians want to dovetail those requirements with the new record-keeping regulations, they can add that device information to the OSHA 300 log by including it on the OSHA 301 form, which asks for more detailed information on the incident, an OSHA official tells HIC.
"Even though the 300 form would say, needlestick, left hand,’ the 301 form then asks for more detail about that equipment," the OSHA official explains. "But it does not go as far as the needlestick rule which asks for the type and brand of device. What we have said is that people can use the 300 log for their needlestick log if they add the additional information to it — the type and brand. That would really be the difference."
On the other hand, those that want to keep the logs separate can do so, and some are expected to generate data for both logs from the same computer system.
What about inspections?
Will the expected surge in numbers trigger OSHA inspections? Not immediately, HIC has learned. OSHA has not planned any special inspection program for the upcoming requirements and, for their part, health care worker safety advocates will not be surprised when the injury reports start to rise.
"I think initially people are going to be shocked at how many needlesticks there really are," says Bill Borwegen, health and safety director at the Service Employees International Union in Wash-ington, DC.
"We certainly are sympathetic to the reality that there has been underreporting for years. That wouldn’t cause us concern if we see skyrocketing needlestick rates because a lot of them have not been reported in the past," he says. "The data are going help ICPs make arguments to their supervisors about why they need to buy the best safer needles."
OSHA’s record-keeping requirements provide data for the Bureau of Labor Statistics Occupational Injury and Illness Survey, the primary source of statistical information concerning workplace injuries and illnesses. The bureau collects the data and publishes the statistics, which OSHA interprets and uses to enforce its regulations.
"The numbers will look high, but then [OSHA] will expect the numbers to go down," West says. "For facilities where they don’t, then there may be an inspection because that may signal that they haven’t implemented needle safety systems. But I don’t think anybody should object to this. There has been a lot of argument about the [additional] work required by the ergonomics standard.
"I don’t think that there is anybody that would argue that needle safe devices and decreasing needlestick injuries is not a good thing."
(Editor’s note: The OSHA record-keeping rule and related materials are available on OSHA’s Web site at http://www.osha-slc.gov/recordkeeping/index.html.)
1. Fed Reg 66; 13:5,915-6,135 (Jan. 19, 2001).
2. Fed Reg 66; 12:5,3175,325 (Jan. 18, 2001).