What Is OSHA Needlestick Protocol?

OSHA Needlestick Protocol Guidelines

Standard 29 CFR 1910.1030 on bloodborne pathogens provides guidelines on the OSHA process on needlestick incidents. These guidelines are adapted from the OSHA FactSheet on Bloodborne Pathogens Standard, which summarizes 29 CFR 1010.1930. Employers should still refer to the original document for detailed guidelines.

Develop a written exposure control plan

The employer should draft an exposure determination outlining job classifications in two categories: all employees are at risk of needlestick incidents, and only certain workers encounter them. The determination should also detail workers’ tasks and procedures that lead to exposure.

Update the plan yearly

The plan should be revised annually, incorporating any changes in responsibilities, tasks, or processes that affect work-related incidents. Employers should also include if they considered and adopted safer medical devices, such as needleless technology, to help lessen or prevent needlestick injuries. Furthermore, employers should record gathered feedback from frontline workers to identify, assess, and select the best engineering and work practice controls.

Implement the use of universal precautions

All human blood and Other Potentially Infectious Materials (OPIM) should be treated as if they are known to be infectious for bloodborne pathogens. Regardless of the perceived status of the blood or OPIM, precautions should be taken to prevent exposure to bloodborne pathogens. In this case, it’s better to assume the worst rather than be sorry in the future.

Use engineering controls

Engineering controls are physical or mechanical solutions that isolate or eliminate exposure to bloodborne pathogens hazards in your workplace. Employers should consider using medical devices such as sharps disposal containers, syringes with safety protection, needle-free injections, and splash guards. The Texas Health and Human Services list of registered needless systems and sharps devices can help you find an appropriate device. 

Improve work processes

Faulty work processes can sometimes lead to OSHA violations and needlestick incidents. Improving workplace practices can help reduce potential exposure to bloodborne pathogens caused by needlesticks. For example, employers should assess whether healthcare staff has disposed of contaminated needles properly, according to the standards of biohazard waste disposal. They should also check if their facilities have readily available puncture-proof containers. Furthermore, they should have a system for reporting improperly disposed of needles.

Provide free PPE

Different OSHA standards, including the one on bloodborne pathogens, require employers to provide personal protective equipment to employees at no cost. If the employee’s job exposes him to needlesticks, employers should give them the appropriate attire, including gloves, eye masks or shields, and closed-toe shoes.

Vaccinate workers against hepatitis B

Healthcare workers exposed to needlesticks should be vaccinated against HBV for free. The vaccination should be given after the employee completes the required training and within ten working days of their initial assignment. If the employee declines the vaccination, the employer should make him sign the statement in Appendix A in the standard. If the employee changes their mind, the employer should still give them the vaccination for free.

Provide post-exposure evaluation and follow-up to exposed workers

Healthcare staff occupationally exposed to blood or OPIM should undergo free evaluation and follow-up. This process should include documentation of the route of exposure and how the exposure happened unless it’s impossible to do so. Employers should get consent from employees before determining HBV and HIV infectivity. If the employee doesn’t consent, it’s up to the employer to establish that legally required consent cannot be obtained.

Use warning labels

Hazard communication is an important aspect of OSHA standards for needlestick injury prevention. Employers should ensure that refrigerators, freezers, and other containers of contaminated needles are clearly labeled. As an alternative, they can also use red bags or red containers. Signage should also be present on all access doors in HIV and HBV research labs and production facilities with OPIM or infected animals.

Educate and train workers

Employers are responsible for regularly training workers with occupational exposure to needlesticks and other sharps. The training should be conducted by a person knowledgeable on the subject matter. Additional training is required for staff working in HIV and HBV laboratories and production facilities.

Keep records of occupational exposure

Employers should follow the standards of the OSHA 300 log to keep accurate records of occupational exposure. Employers with ten or fewer employees are exempted from routinely keeping records as required in Part 1904-Recording and Reporting Occupational Injuries and Illnesses. However, any serious workplace incident that results in a fatality or in-patient hospitalization should still be reported to OSHA immediately, according to the required timeframes.