OSHA directive requires hospitals to implement safer needle technology
Mandate puts focus on device evaluation, training
The move toward safer needle devices has become a national mandate as the U.S. Occu pational Safety and Health Administra tion (OSHA) has issued a directive requiring the use of "effective engineering controls" to prevent needlestick injuries.
While OSHA previously cited hospitals that failed to evaluate and use safer devices, this updated compliance directive makes clear what actions hospitals should be taking concerning occupational exposure to bloodborne pathogens. "There are a lot of commercially available products, and you should be using them to [prevent injuries]," says Melody Sands, director of OSHA’s office of health compliance assistance.
Experts in needle safety hailed the directive as a milestone in the long effort to protect health care workers from needlesticks. "This is the recommendation I’ve been making for years, [to adopt safer devices]," says Janine Jagger, PhD, MPH, director of the International Health Care Worker Safety Cen ter at the University of Virginia in Charlottesville. "There was no regulatory clout behind it. Now, we have that clout."
Safer devices could reduce sharps injuries by more than 70%, Jagger says. It is estimated that health care workers suffer more than half a million needlestick injuries annually.
Some union leaders say they will monitor hospital compliance with the new OSHA directive and file complaints against those facilities that don’t show a good-faith effort. In fact, complaints in California and Ohio have used existing state laws and federal regulations to force a move toward safer devices. (See related article on p. 4.)
"Now that the compliance directive is out, there will be a very organized effort to involve front-line workers in reporting to OSHA when safer devices have not been utilized," says Susan Wilburn, RN, MPH, senior specialist for occupational safety and health with the American Nurses Association in Washington, DC.
Meanwhile, the directive, which updates one published eight years ago, isn’t the final word on safer needle devices. Legislation is still pending in Congress to require the use of needleless systems and safety mechanisms, enhance reporting of needlestick injuries, and create a national clearinghouse on safer technologies.
"This is a great development. This is tremendous progress, but the job isn’t done yet," says Wilburn, whose organization wants a national injury record system and new wording in the OSHA standard itself.
OSHA has announced plans to revise the bloodborne pathogens standard by next fall. And the upcoming record-keeping rule, due out next year, will require hospitals to report all needlestick injuries, not just those that result in seroconversion, Sands says.
To find out what is currently expected of them, hospitals need only look as far as the appendices of the updated directive. OSHA provides sample device evaluation forms, committee structures, and a sample exposure control plan, as well as Internet links and copies of the Centers for Disease Control and Prevention (CDC) guidelines. The directive does not mention any specific needle devices, but lists of devices can be found on the Web sites of the Sharps Injury Control Program in San Francisco (www.ohb.org/sharps. htm) and the International Health Care Worker Safety Center (www.med.virginia.edu/medcntr/centers/ epinet/links.html).
For example, in an exposure control plan that must be updated at least annually, employee health clinicians must consider all potentially hazardous situations and how they could be avoided through the use of "engineering controls" (or safer devices). Hospitals must consider how the devices would function in the working environment, and they will be expected to rely on the ample literature on device safety, says Sands.
Act like it’s your family you’re protecting
"Hundreds of thousands of needlestick injuries occur each year, and the prevalence of bloodborne pathogens is growing, particularly hepatitis C," says Sands. "You should implement these controls wherever feasible. Look at your exposure control plan as if your family was out there. What would you do to keep them from getting stuck?"
Just choosing a device won’t be enough. As newer and better products become available, employee health clinicians will need a mechanism for re-evaluating the devices. (See related article on p. 6.)
"If a compliance officer sees someone using an engineering control but believes another one would be more effective, they would not immediately issue a citation," says Sands. "They would coordinate with the bloodborne pathogens coordinator [in that region]. That’s going to be a judgment call. We’ll deal with that on a case-by-case basis. It would have to clearly be more effective."
The new directive doesn’t mean every conventional sharp device must be eliminated from hospitals. For example, if a needle is used only to draw medication, such as in a pharmacy, and there is no potential for employee exposure to bloodborne pathogens, then a conventional needle can be used, says Sands.
"Exposure is always key for OSHA to find a hazard," says Sands.
The directive also clarifies actions employers must take if an employee is exposed, explicitly requiring hospitals to follow appropriate guidelines of the CDC. Postexposure evaluation and follow-up must occur "as soon as possible after exposure," the directive states.
The CDC guidelines were previously voluntary, but most employee health offices followed them, says Mary Ann Gruden, MSN, CRNP, NP-C, COHN-S/CM, executive president of the Association of Occupational Health Professionals in Healthcare in Reston, VA, and employee health nurse practitioner at Sewickley (PA) Valley Hospital.
"It reinforces employee health practices that are already occurring," says Gruden. "If an employee health office is not following these standards, this is an opportune time to implement them."
The directive exacerbates the demand for safer devices, which surged after the passage of a needle safety law in California last year. In fact, hospitals are reporting delays in obtaining products and demonstrations or training from vendors.
"Right now, the issue is going to be the availability of devices," says June Fisher, MD, director of the Training for Development of Innovative Control Technology (TDICT) project, which is based at the Trauma Foundation of San Francisco General Hospital.
Catholic Healthcare West, a 48-hospital system based in San Francisco, faced delays in trying to get ready by the July 1 deadline set by the California needle safety law, says Cynthia Fine, RN, MSN, CIC, infection control and employee health program consultant.
"It was really difficult to be able to get enough product to do that pilot [testing] and then to get enough to stock the hospitals," she says. "There are shortages all over."
However, the new demand may have positive effects, as prices decline and companies develop devices that are even safer and simpler to use.
Training is another concern for employee health practitioners. The OSHA directive specifies that training sessions should be "interactive," giving employees an opportunity to ask questions.
A device isn’t really safer unless the employees know how to use it properly, notes Wilburn. The American Nurses Association is teaming with TDICT to offer workshops around the country on preventing needlesticks and evaluating safer needle devices.
"With any new device, the proof [of effectiveness] is not really in the implementation of the device. The proof is in preventing needlestick injuries," she says. "Even with the best device, you still have to train the health care worker so it’s implemented successfully."
Health care workers may initially feel frustrated with new devices, particularly if their use takes a little more time and care, says Fine.
"It is a big change in technique. Even though they knew staff was involved in the assessment, I think it’s still hard for them," she says. "Any thing that takes a little bit more of their time is difficult."
(Editor’s note: A copy of the compliance directive is available on OSHA’s Web site at www.osha.gov.)
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