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The Bloodborne Pathogens Standard and the Needlestick Safety & Prevention Act: Not Just for OSHA Compliance

Often companies seek to check off all of the regulatory boxes so non-compliance doesn’t interfere with their work and timelines. While this may be reasonable, regulations can be general and do not always achieve safety standards that appropriately address workplace hazards.

The OSHA Bloodborne Pathogens Standard went into effect in 1991 and was updated in 2001 to incorporate the requirements of The Needlestick Safety and Prevention Act.

This Standard is an example of a sweeping and effective regulation that has significantly reduced the risk of occupational transmission of bloodborne viruses.

In this post, we’re going to focus on the Needlestick Safety and Prevention Act and the changes that have been made to reduce sharps injuries. The Act itself is only four pages and lays out the problem (occupational exposure to contaminated sharps), the empirical evidence for the need to resolve it, and specifies the requirements related to sharps with engineered sharps injury protections that were added to the Bloodborne Pathogens Standard.

Partially inspired by the AIDS crisis, new safer sharps technologies were developed (e.g. self-sheathing scalpels, retractable needles, etc.) that decreased the risk of percutaneous injuries to the frontline healthcare workers.

However, there was no mandate for hospitals and laboratories to acquire and provide these safer devices until the Bloodborne Pathogens Standard was updated to incorporate the requirements of the Needlestick Safety and Prevention Act.

One of the requirements that were incorporated into the Standard is that companies must “solicit input from non-managerial employees” who are potentially exposed to injuries from contaminated sharps for the identification, evaluation, and selection of effective engineering and work practice controls to improve the sharps program.

Meeting this requirement is often fulfilled by having employees complete a Safer Sharps Survey annually.

This requirement may be viewed as an overly arbitrary box to check each year strictly for OSHA compliance without much tangible benefit. However, I have personally seen tangible benefits that have resulted from conducting a Safer Sharps Survey of employees who work in biological labs where there is potential exposure to bloodborne pathogens.

In one case, I was managing a biosafety level 2 histology lab that had a process involving a straight razor that had to be scraped on plastic by employees who were required to wear nitrile gloves. Some staff had to do this process for hours at a time, and there were multiple associated sharps injuries in my first year.

During the first Safer Sharps Survey that I administered, one of the staff heavily involved in this process had researched a Kevlar glove that when worn with nitrile gloves would significantly reduce the sharps injuries caused by this process.

As a result of the information that she had researched, 30 pairs of gloves were purchased for staff who conducted this process and sharps injuries dropped, well… sharply!

In another case, I administered a Safer Sharps Survey at a biotechnology lab where blood was handled. As a result of the survey, two people volunteered to form a Safer Sharps Committee that proactively improved the various sharps used throughout the lab. The volunteers were divided into Operations (i.e. non-lab) and Laboratory “Sharps Officers.”

After an initial evaluation and interviews of the lab and non-lab workers, the Committee identified a process involving crimped foil that workers cut their hands-on, unprotected razors in lab drawers and several pieces of chipped glassware.

Solutions were then implemented to address these issues. Given the high-risk nature of occupational transmission of a bloodborne virus, if even one sharps injury was prevented by this Committee, then the Safer Sharps Survey and the Committee that was formed were a success, not just a box to check to meet your OSHA requirements!

Occupational transmission of the hepatitis B virus (HBV) and HIV has plummeted since the Bloodborne Pathogens Standard was implemented. However, acute cases of hepatitis C virus (HCV) and some localized increases in HBV are on the rise (some theorize in part because of the opioid crisis).

Also, unlike HBV, there is no vaccine for HCV. Therefore vigilant engagement with safer sharps programs and going beyond fulfilling the minimum regulatory requirements in that engagement is critical to prevent the tragedy of bloodborne pathogen transmission.

This guest blog is written by Bernard Paniccia, HTL, and Consulting Safety Officer at Safety Partners.

Be on the lookout for our online Bloodborne Pathogens Standard training coming soon! Stay up to date on our training page here.

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