Clarifying Employer Requirements under the OSHA Bloodborne Pathogens Standard
Thank you for publishing such an important article on sharps safety and protecting healthcare personnel from needlesticks (“The truth about sharps injuries? They still happen.” December 2019 Repertoire). Reading the piece provides a great opportunity to clarify the requirements under the Bloodborne Pathogens Standard and the impact the Needlestick Safety and Prevention Act (NSPA) had on the standard and on the regulated public.
The original OSHA Bloodborne Pathogens Standard (BPS) was promulgated in 1991 with the requirement for employers to comply with all of its provisions in 1992. The original standard included, among many other things, mandating making and maintaining an Exposure Control Plan, the use of engineering controls and safe work practices, use of personal protective equipment (PPE), hepatitis B vaccine, annual training, labeling biohazard waste, and more. The standard was then and is today the most cited standard during inspections in healthcare facilities (https://www.osha.gov/pls/imis/citedstandard.naics?p_esize=&p_state=FEFederal&p_naics=62).
In 2000, the Needlestick Safety and Prevention Act was passed unanimously by Congress. The Act required OSHA to update its standard to include additional provisions for better protections of healthcare workers, specifically related to preventing sharps injuries. This happened for many reasons, including high rates of sharps injuries occurring despite better, safer medical device designs available on the market. OSHA needed renewed focus to prevent ongoing exposures to blood, body fluids, and other potentially infectious materials. The additional provisions (https://www.osha.gov/SLTC/bloodbornepathogens/bloodborne_quickref.html) included:
- OSHA’s requirement for employers to identify, evaluate and implement safer medical devices such as needleless systems and sharps with engineered sharps protections.
- Additional requirements for maintaining a sharps injury log and for the involvement of non-managerial healthcare workers in identifying, evaluating and choosing effective engineering and work practice controls.
The revised standard was in place with these additional requirements in 2001 and was then enforceable during inspections in April in Federal OSHA States and in July in OSHA State Plan States. Enforcement relative to the standard stays consistent over time (Mitchell, 2019).
It is important for healthcare employers to know that compliance with the BPS is mandatory. This includes not only the elements of the original 1991 standard, but also the 2001 standard. A critical piece of protecting healthcare personnel from sharps injuries and needlesticks is not only the use of safer medical devices with sharps injury prevention features, but also the safe activation of those features and immediate disposal into a sharps container. This works to protect not only them, but any employee downstream. In fact, more than 25% of all injuries occur to non-users of devices (EPINet 2018). This means that failure to safely use, activate, and dispose of a sharp device is responsible for causing injuries in co-workers and colleagues. This must stop. Use of safer medical devices is a crucial piece of protecting the health and safety of all personnel in setting where they are used.
2020 is the 20th anniversary of the NSPA and we still have a long way to go to make safer work environments for those providing patient care. Injuries from disposable syringes and sutures continue to be unacceptably high. It is important for healthcare institutions to carefully measure their injury and exposure incidents so they can put controls in place to prevent them in the future.
Amber Hogan Mitchell, DrPH, MPH, CPH
President / Executive Director
International Safety Center
References
Mitchell et al. Bloodborne Pathogens Standard Enforcement at the Occupational Safety and Health Administration: The First Twenty-Five Years. New Solutions; A Journal of Environmental and Occupational Health Policy. March 2019. https://journals.sagepub.com/doi/abs/10.1177/1048291119840077
International Safety Center. EPINet Report for Needlestick and Sharp
Object Injuries. 2018. https://internationalsafetycenter.org/wp-content/uploads/2019/07/Official-2018-US-NeedleSummary-FINAL.pdf