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What OSHA Has to Say about Employers, Needles, & Safety

Is My Employer Breaking the Rules?
 
Every so often, particularly after a "close call" with a needle procedure, the question arises in a medical technician's mind, "Is my employer breaching some responsibility here? Is management evading and shirking some rules to save money?"
 
OSHA developed Information Regarding the Disposal of Contaminated Needles and Blood Tube Holders Used for Phlebotomy to provide information regarding OSHA's policy on the prohibition of contaminated needle removal from medical devices. The guidelines are just that - guidelines only. This is not a new law or regulation, so failure to follow the guidelines is not an OSHA violation. OSHA can only issue a citation when the employer violates an actual Act, such as the Occupational Safety and Health Act, which directs employers to provide a safe workplace.
 
These are the guidelines for employers when it comes to disposing needles and holders:
 
1. Employers must first evaluate, select, and use appropriate engineering controls (e.g., sharps with engineered sharps injury protection), which includes single-use blood tube holders with sharps with engineered sharps injury protection (SESIP) attached.
 
2. The use of engineering and work practice controls provide the highest degree of control in order to eliminate potential injuries after performing blood draws. Disposing of blood tube holders with contaminated needles attached after the activation of the safety feature affords the greatest hazard control.
 
3. In very rare situations needle removal is acceptable.
 
a. If the employer can demonstrate that no feasible alternative to needle removal is available (e.g. inability to purchase single-use blood tube holders due to a supply shortage of these devices),
b. If the removal is necessary for a specific medical or dental procedure.
 
In these rare cases, the employer must ensure that the contaminated needle is protected by a SESIP prior to disposal. In addition, the employer must ensure that a proper sharps disposal container is located in the immediate area of sharps use and is easily accessible to employees. This information must be clearly detailed and documented in the employer's Exposure Control Plan.
 
4. If it is necessary to draw blood with a syringe, a syringe with engineered sharps injury protection must be used in which the protected needle is removed using safe work practices, and transfer of blood from the syringe to the tube must be done using a needleless blood transfer device. 
 
How does your employer stack up against OSHA's guidelines? For more information about worker safety, check out OSHA's website at www.osha.gov.
 

By Michelle Simmons
Get Phlebotomy Jobs, Contributing Editor

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