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Employer’s Responsibility To Re-evaluate Engineering Controls, i.e., Safer Needle Devices, At Least Annually

Friday, December 9th, 2011 | Permalink

January 20, 2004 Mr. Marty Salanger Manager of Safety, Policy and Government Relations BD Advanced Protection Technologies 1 Becton Drive Franklin Lakes, NJ 07417 Dear Mr. Salanger: Thank you for your October 29, 2003 letter to the Occupational Safety and Health Administration’s (OSHA’s) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA’s interpretation only of the requirements discussed and may not be applicable to any question(s) not delineated within your original correspondence. You had specific questions regarding an employer’s responsibility to re-evaluate engineering controls under OSHA’s bloodborne pathogens standard (29 CFR 1910.1030).

Your question is restated below followed by OSHA’s response. We apologize for the delay in responding. Question: If an employer has selected a particular safety-engineered device based on employee feedback, and a reduction in needlestick injuries can be shown as a result of the adoption of the current device, to what extent does an employer need to re-evaluate their chosen device?

Reply: As you are aware, OSHA’s bloodborne pathogens standard requires employers to review and update their Exposure Control Plan (ECP) at least annually [29 CFR 1910.1030(c)(1)(iv)]. It is also a requirement that: 1) annual reviews and updates of ECPs reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens; and 2) employers document annually their consideration and implementation of appropriate commercially available and effective safer medical devices [29 CFR 1910.1030(c)(1)(iv)(A-B)]. If, after employee input, an employer selects an engineering control that is effective in reducing needlestick injuries, it is not necessary to evaluate all newly emerging engineering controls each year. The employer must simply keep abreast of new and emerging technologies and solicit input from non-managerial employees to determine if the facility’s chosen device remains preferable to any newly developed products. This should be documented in the ECP. Since the requirements of the standard are performance-based, OSHA determines compliance with the standard on a facility-by-facility, instance-by-instance basis, based on the employer’s consideration of safer medical devices, solicitation of input from employees, documentation in an employer’s ECP, and employee interviews.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA’s interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA’s website at . If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190. Sincerely, Richard E. Fairfax, Director Directorate of Enforcement Programs —————————————————– ~ ~ ~ Needlestick Injuries, Legislation and More…

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Employer’s Responsibility To Re-evaluate Engineering Controls, i.e., Safer Needle Devices, At Least Annually

OSHA Answers Questions Regarding The Needlestick Prevention Act

Saturday, December 3rd, 2011 | Permalink

Does the standard apply to public sector (State and local government) employees? Federal OSHA standards do not apply to public sector employees, but the 24 states and two territories that operate OSHA-approved state plans are required to enforce an “at least as effective” standard in the public sector. Does the “Needlestick Act” apply to me? OSHA’s Bloodborne Pathogens Standard, including its 2001 revisions, applies to all employers who have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials (OPIM). These employers must implement the applicable requirements set forth in the standard. Some of the new and clarified provisions in the standard apply only to healthcare activities, but some of the provisions, particularly the requirements to update the Exposure Control Plan and to keep a sharps injury log, will apply to non-healthcare as well as healthcare activities. By what date do we have to implement safer medical devices? The requirement to implement safer medical devices is not new. However, the revised standard further clarifies what is meant by “engineering controls” in the original 1991 Bloodborne Pathogens standard by adding language to the definition section of the standard that reflects the development and availability of new safer medical devices over the last decade. The 1991 standard states, “engineering and work practice controls shall be used to eliminate or minimize employee exposure.” The revision defines Engineering Controls as “controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.” Consequently, you should already have safer devices in place. If you have not already evaluated and implemented appropriate and available engineering controls, you must do so now. Also, employees with occupational exposure to blood and OPIM must be trained regarding the proper use of all engineering and work practice controls. What if I’ve never had an employee experience a needlestick, do I still need to use safer devices? Yes. OSHA standards are intended to be implemented as a means to prevent occupational injuries and illnesses. In order to most effectively avoid percutaneous injuries from contaminated sharps, employees must use engineering controls, including safer medical devices. How many non-managerial employees do I need to include in the process of choosing safer medical devices? Small medical offices may want to seek input from all employees when making their decisions. Larger facilities are not required to request input from all exposed employees; however, the employees selected should represent the range of exposure situations encountered in the workplace (e.g., pediatrics, emergency department, etc.). The solicitation of employees who have been involved in the input and evaluation process must be documented in the Exposure Control Plan. Does OSHA have a list of available safer medical devices? No. OSHA does not approve or endorse any product. It is your responsibility as an employer to determine which engineering controls are appropriate for specific hazards, based on what is appropriate to the specific medical procedures being conducted, what is feasible, and what is commercially available. What if a safer option is not available for the medical device that I use? A key element in choosing a safer medical device, other than its appropriateness to the procedure and effectiveness, is its availability on the market. If there is no safer option for a particular medical device used where there is exposure to blood or OPIM, you are not required to use something other than the device that is normally used. During your annual review of devices, you must inquire about new or prospective safer options and document this fact in your written Exposure Control Plan. With increasing medical technology, more devices are becoming available for different procedures. If no engineering control is available, work practice controls shall be used and, if occupational exposure still remains, personal protective equipment must also be used.

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OSHA Answers Questions Regarding The Needlestick Prevention Act

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