Revised Bloodborne Pathogens Standard WAC 296-823 Safer Medical Device and Sharps Injury Recordkeeping Requirements

1. Revised Bloodborne Pathogens Standard WAC 296-823Safer Medical Device and Sharps Injury Recordkeeping Requirements

2. Bloodborne Pathogens Standard • Federal 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens - Effective March 1992 • WAC 296-823 Effective January 1993 • Scope “This chapter applies to you if you have employees with occupational exposure to blood or OPIM, even if no actual exposure incidents have occurred”

3. Bloodborne Pathogens Standard Major Provisions by Section: 110 – Planning 120 – Training 130- Hepatitis B (HBV) Vaccinations 140 – Control Employee Exposure 150- Personal Protective Equipment 160- Post Exposure Requirements 170 – Records 180 Additional Requirements for HIV and HBV Research Labs and Production Facilities

4. Occupational Exposure “Means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of an employee’s duties”

5. Methods of Compliance • Infection Control systems • Controlling exposure through selection and implementation of safer medical devices and administrative controls • Personal protective equipment • Housekeeping • Regulated waste management • Laundry handling • Signs and labeling

6. Use of Safer Medical Devices • Since 1992: • Advancements in medical technology • Union and Congressional involvement • November 1999, OSHA releases CPL 2-2.44D • November 2000, Needlestick Safety and Prevention ACT P.L. 106-430

7. Needlestick Safety and Prevention Act Timeline • P. L. 106-430 signed; November 6, 2000 • Revised Standard published in Federal Register; Jan. 18, 2001 • Effective date; April 18, 2001 • Federal enforcement of new provisions; July 17, 2001 • WISHA enforcement: Aug. 6, 2001

8. 2001 Revisions to Standard • Further clarifies the definition of Safer Medical devices • Requirements to document evaluation of and changes in the use of safer medical devices • Requires solicitation of input from non-managerial employees • Maintenance of a Sharps Injury Log

9. Safer Medical Devices “Medical devices that have been engineered to reduce the risk of needlesticks and other contaminated sharps injuries. These include not only sharps with engineered sharps injury protections and needleless systems but also other medical devices designed to reduce the risk of sharps injury exposures”

10. Needleless SystemsNew Definition • Device that does not use a needle for: • Collection of bodily fluids • Administration of medication/fluids • Any other procedure with potential percutaneous exposure to a contaminated sharp

11. “Sharps with Engineered Sharps Injury Protections (SESIP)”New Definition Non-needle sharp or a needle with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident.

12. Hypodermic syringes with “Self-Sheathing” safety feature Self-sheathed protected position

13. Hypodermic syringes with “Retractable Technology” safety feature Retracted protected position

14. Phlebotomy needle with “Self-Blunting” safety feature Blunted protected position

15. “Add-on” safety feature Attached to syringe needle Attached to blood tube holder

16. Retracting lancets with safety features Before During After Before During After In use After use

17. Disposable scalpels with safety features Retracted position Protracted position Protracted position

18. Additional Information About Safety Devices Available At… www.med.virginia.edu/~epinet www.tdict.org www.osha.gov www.lni.wa.gov/wisha/

19. Exposure Control Plan: The ECP must be updated to include: • changes in technology that reduce/eliminate exposure • annual documentation of consideration and implementation of safer medical devices • solicitation of input from non-managerial employees

20. Solicitation of Non-Managerial Employees • Identification, evaluation, and selection of safer medical devices • Must select employees that are: • Responsible for direct patient care • Representative sample of those with potential exposure

21. Controlling Employee Exposure Employers must select and implement appropriate safer medical devices to reduce or eliminate employee exposure.

22. “Where safer medical devices will reduce employee exposure either by removing, eliminating, or isolating the hazard, they must be used.” CPL 2-2.44D

23. Safer Medical Devices • The employer must: • Evaluate available safer medical devices • Train employees on safe use and disposal when needed • Implement appropriate devices

24. Controlling Employee Exposure Selection of safer medical devices and work practice controls is dependent on the employer’s Exposure Determination.

25. Exposure Determination • The employer must: • Identify worker exposures to blood or OPIM • Review all processes and procedures with exposure potential • Re-evaluate when new processes or procedures are used

26. Safer Medical Devices • The employer must: • Document evaluation and implementation in ECP • Review, update ECP at least annually • Review new devices and technologies annually • Implement new device use, as appropriate and available

27. Safer Medical Devices (con’t) • The employer must: • Train employees to use new devices and/or procedures • Document in ECP

28. Phlebotomy Needles • Section 823-14010 prohibits bending, recapping, or removal of needles or other contaminated sharps unless you can demonstrate that there is no feasible alternative • Routine removal of phlebotomy needles from the holder is prohibited.

29. Recordkeeping • Sharps Injury Log • Documents all contaminated sharps exposures • Must also be documented on OSHA 300 Log • Confidential record • Sharps exposure must be documented separately from other injuries

30. Sharps Injury Log At a minimum, the log must contain, for each incident: • Type and brand of device involved • Department or area of incident • Description of incident (may be documented on the 301 form)

31. Summary • Additional definitions • New requirements to evaluate existing medical devices and implement safer technologies • Non-managerial employees involved in selection of safer medical devices • Sharps injury log

32. Department of Labor and Industries WISHA Services Division Policy and Technical Services John Furman (360) 902-5666 Furk235@lni.wa.gov