Posts Tagged injuries

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

Do We Have To Keep A Sharps Injury Log?

Saturday, December 3rd, 2011 | Permalink

What if the safer device that I choose is on back order? Safety equipment must be available at all times. If for some reason an engineering control is not available (due to supply shortages, back orders, shipping delays, etc.), this must be documented in your Exposure Control Plan. You would then be responsible to implement the chosen control(s) as soon as it becomes available and adjust your exposure control plan to illustrate such. In the meantime, work practice controls must be used and, if occupational exposure still remains, personal protective equipment must also be used.

Do I have to keep a sharps injury log? Does it have to be confidential?

If, as an employer, you are required to maintain a log of occupational injuries and illnesses under 29 CFR 1904, you must also establish and maintain a sharps injury log for recording percutaneous injuries from contaminated sharps. The Sharps Log must contain, at a minimum, information about the injury, the type and brand of device involved in the injury (if known), the department or work area where the exposure occurred, and an explanation of how the incident occurred. The log must be recorded and maintained in such a manner so as to protect the confidentiality of the injured employee (e.g., removal of personal identifiers).

Does the revised Bloodborne Pathogens Standard apply to medical or dental offices that have fewer than 10 employees?

OSHA’s Bloodborne Pathogens Standard applies to all employers with employees who have occupational exposure to blood or other potentially infectious materials (OPIM), regardless of how many workers are employed. However, workplaces with 10 or fewer employees are exempt from OSHA recordkeeping requirements and are also exempt from recording and maintaining a Sharps Injury Log. (See 29 CFR 1904 for applicability of recordkeeping requirements). All other applicable provisions of the Bloodborne Pathogens Standard still apply.

What new information do I need to include in my written Exposure Control Plan?

How often to I need to update it? In addition to what is already required by the 1991 standard, the revised standard requires the documentation of (1) annual consideration and implementation of appropriate engineering controls, and (2) solicitation of non-managerial healthcare workers in evaluating and choosing devices. The plan must be reviewed and updated at least annually.

Where can I get information about what is expected of me?

There are several resources available for employers and employees with regard to occupational exposures to blood and OPIM. First, of course, is the OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030). Also available are “CPL 2-2.69 (November 2001). Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, and many other related documents. You may access this information, as well as information from OSHA’s Consultation and State Plan State Offices, via OSHA’s website at or by phone at 1-800-321-OSHA. The National Institute for Occupational Safety and Health (NIOSH) and the Centers for Disease Control and Prevention (CDC) also have several documents related to the prevention of occupational exposure to blood and OPIM.

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Do We Have To Keep A Sharps Injury Log?


Friday, October 21st, 2011 | Permalink

by AnestaWeb, Inc. QD Syringe Systems Describing In Detail The Unsafe Practice Of Drawing Medications Into Vials With Steel Needles.


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