Providers face new reporting requirements
New reporting requirements from the Occupational Safety and Health Administration may make it easier to ascertain just how many sharps injuries and/or needlesticks are incurred every year by healthcare workers. The agency is betting that the requirements will “nudge” providers to take extra steps to safeguard their employees.
Under the Federal Occupational Safety and Health Act, employers must provide their workers with worksites free of recognized serious hazards. To that end, OSHA has for decades required employers to keep track of their workers’ injuries and illnesses by recording them in what is often called an “OSHA log.”
But under a final rule that became effective January 1, 2017, OSHA now requires that some of this recorded information be submitted to OSHA electronically for posting to the OSHA website. OSHA hopes that releasing the data in standard, open formats will:
- Encourage employers to increase their efforts to prevent worker injuries and illnesses, and, “compelled by their competitive spirit, race to the top in terms of worker safety.”
- Enable researchers to examine these data in ways that may help employers make their workplaces safer and healthier and may also help to identify new workplace safety hazards before they become widespread.
In addition, the final rule includes provisions that encourage workers to report work-related injuries or illnesses – including sharps injuries – to their employers, and prohibits employers from retaliating against workers for making those reports.
“[B]ehavioral science suggests that public disclosure of the data will ‘nudge’ employers to reduce work-related injuries and illnesses in order to demonstrate to investors, job seekers, customers, and the broader public that their workplaces provide safe and healthy work environments for their employees,” says OSHA on its website. “Currently, employers cannot compare their injury experience with other businesses in their industry; they can only compare their experience with their industry as a whole. Access to establishment-specific data will enable employers to benchmark their safety and health performance against industry leaders, encouraging them to improve their safety programs.”
More data needed
“Since OSHA hasn’t yet released its electronic reporting portal for uploading forms, it’s hard to tell if this will be easy or take some time” for providers to comply with the new reporting requirements,” said Amber Mitchell, DrPH, MPH, CPH, International Safety Center president and executive director. As of press time, the majority of providers with whom she had spoken were uncertain of the impact the new requirements would have on them.
“As long-time occupational health practitioners, we are happy about [the new reporting rule], since current national estimates of all injuries and illnesses are gravely under-reported with no federal reporting requirement in place,” she says. “Without data, we don’t have resources available to adequately protect working Americans. We know what affects our patients, and we have essentially no idea how caring for patients affects our healthcare worker population. This isn’t right, or fair.”
The nonprofit International Healthcare Worker Safety Center, originally housed at theUniversity of Virginia, focuses on collecting and analyzing data that identifies healthcare worker safety hazards. The Center conducts epidemiological research, surveillance, and outreach on sharps injuries, needlesticks, blood, and body fluid exposures. Its work is fueled in part by its free occupational injury and exposure surveillance tool – the Exposure Prevention Information Network (EPINet®).
The OSHA log
Employers have been required to keep an Occupational Injury and Illness Log ever since the OSHA Recordkeeping Rule (29 CFR 1904) was implemented in the early 1990s. Traditionally, the logs have been requested by OSHA Compliance Safety and Health Officers (CSHOs) during OSHA inspections, or by the Bureau of Labor Statistics in the course of surveying a particular industry.
OSHA says that the logs protect both employers and employees by:
- Identifying which high-risk hazards need focus based on the number and severity of injuries or illnesses recorded.
- Identifying which job functions or tasks result in an undue number of injuries or illnesses, so they can be addressed through training, controls, etc.
- Identifying successes (or failures) year after year to determine how controls or interventions are working to prevent exposures.
- Acting as a form of new-employee recruitment and retention to showcase a safer workplace.
- Keeping track of workers compensation or other insurance cases.
Both the OSHA Recordkeeping Rule and the Bloodborne Pathogens Standard (29 CFR 1910.1030) require that employers record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material. In addition, a blood or body fluid exposure that touches non-intact skin and requires medical treatment is also recordable. These incidents must be kept in a Sharps Injury Log, in addition to being captured in the OSHA 300 Log of Work-Related Injuries and Illnesses.
Since keeping both the OSHA 300 and Sharps Injury Logs are already required, providers shouldn’t incur any additional costs associated with the new reporting requirement, says OSHA. Though OSHA has yet to set up its electronic reporting portal, when it does, it will likely be a simple upload function, according to the agency.
Electronic submission requirements
The new electronic reporting requirement applies to the following:
- Workplaces with 250 or more employees that are currently required to keep records from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report.)
- Workplaces with 20-249 employees that are classified in certain industries (including healthcare) with historically high rates of occupational injuries and illnesses.
Beginning in 2019, the submission deadline will be changed from July 1 to March 2. The electronic submission requirements do not change an employer’s obligation to complete and retain injury and illness records.
OSHA will post on its public website (www.osha.gov) establishment-specific injury and illness data it collects under the new rule. The agency says it will remove any personally identifiable information before the data are released to the public. States that operate their own job safety and health programs, also called OSHA State Plan states, must adopt requirements that are substantially identical to the requirements in this rule within six months after publication of the final rule.
For FAQs about the new reporting rule, go to https://www.osha.gov/recordkeeping/finalrule/finalrule_faq.html
For nearly 25 years, the International Healthcare Worker Safety Center – called the International Safety Center since 2015 – has offered free standardized recording and tracking of sharps injuries and blood and body fluid contact through the Exposure Prevention Information Network® (EPINet) database. EPINet has been used in more than 1,500 U.S. hospitals and in almost 100 countries, with some facilities reporting reductions in blood exposures by 40 percent and cost savings of tens of thousands of dollars per year, according to the Center.
Other than EPINet, a few states require healthcare facilities (either all or just public/federal institutions) to submit reports of their sharps injuries to the state department of health or public health, including Massachusetts, Texas, New York and New Jersey, says Amber Mitchell, DrPH, MPH, CPH, International Safety Center president and executive director
EPINet is far more detailed than either the Sharps Injury Log or the OSHA 300 Log, she says. “If a facility is using EPINet, they are not only more prepared than most, they also have access to more information than most on how to prevent injuries and exposures from blood and body fluids from happening.
“EPINet facilities are gold standard facilities. They are going above and beyond to protect their workers from exposures to bloodborne and infectious disease.”
EPINet is free to any healthcare facility in any country around the world, says Mitchell. “Anyone who is interested simply emails us, and we send them all necessary materials, including the manual. We do all onboarding, training, and upkeep. It’s all free.”
EPINet has been the only ongoing occupational surveillance system in the world that measures, analyzes and reports sharp object injuries, needlesticks, and blood/body fluid exposures, she says. “It is an under-utilized and under-appreciated beacon of occupational and public health. Federal agencies like OSHA, NIOSH, CDC and others would not have data in place to justify their ongoing work in this arena if not for EPINet.”
Because EPINet captures more information than the Sharps Injury Log or OSHA 300 Log, it will remain an important source for data for years to come, she continues.
“EPINet users and those obtaining EPINet data on our site are facilities that are interested in establishing not only benchmark comparisons for needlesticks and blood/body fluid exposures, but also using that data to identify what safety devices to use, improving activation of safety features, how to improve PPE compliance/use, establishing what professional groups to focus interventions/campaigns on, etc.
“The Sharps Injury Log and OSHA 300 Logs are not designed to be remotely as actionable as EPINet as it relates to these injury and exposure types. EPINet has been around longer than either of these recordkeeping systems, and we are striving to have it outlast them as well… until there are no occupational illness or injuries associated with exposure to bloodborne or infectious disease.”
At press time, the International Safety Center was preparing to release 2015 EPINet data in June. The Center is currently collecting and analyzing 2016 data.
Editor’s note: To see a sample Blood and Body Fluid Exposure Report from EPINet, go to https://internationalsafetycenter.org/wp-content/uploads/2017/04/US-BBF-2010.pdf
Needlestick Safety and Prevention Act
The Needlestick Safety and Prevention Act (Pub. L. 106-430) came about when Congress required modification of OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) to set forth in greater detail OSHA’s requirement for employers to identify, evaluate and implement safer medical devices, such as needleless systems and sharps with engineered sharps protections. The Act also mandated 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. These are workers who are responsible for direct patient care and who may be potentially exposed to injuries from contaminated sharps.
The standard states, “engineering and work practice controls shall be used to eliminate or minimize employee exposure.” A 2001 revision defines engineering controls as “controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.”
Employers whose employees are exposed to contaminated sharps must consider and implement appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure. Also, employees with occupational exposure must be trained in the use and limitations of methods that will prevent or reduce exposure, including appropriate engineering controls, work practices and personal protective equipment. Training must include instruction on any new techniques and practices associated with new engineering controls.
For more information, go to OSHA’s Bloodborne Pathogens and Needlestick Prevention website at https://www.osha.gov/SLTC/bloodbornepathogens/index.html
OSHA’s Bloodborne Pathogens Standard: The basics
The Occupational Safety and Health Administration published the Occupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030) in 1991 because of a significant health risk associated with exposure to viruses and other microorganisms that cause bloodborne diseases. The standard’s requirements state what employers must do to protect workers who are occupationally exposed to blood or other potentially infectious materials, as defined in the standard.
The standard requires employers to:
Establish an exposure control plan. This is a written plan to eliminate or minimize occupational exposures. The employer must prepare an exposure determination that contains a list of job classifications in which all workers have occupational exposure and a list of job classifications in which some workers have occupational exposure, along with a list of the tasks and procedures performed by those workers that result in their exposure.
Update the plan annually to reflect changes in tasks, procedures, and positions that affect occupational exposure, and also technological changes that eliminate or reduce occupational exposure. In addition, employers must annually document in the plan that they have considered and begun using appropriate, commercially available, effective, safer medical devices designed to eliminate or minimize occupational exposure. Employers must also document that they have solicited input from frontline workers in identifying, evaluating, and selecting effective engineering and work practice controls.
Implement the use of universal precautions (treating all human blood and other potentially infectious materials as if known to be infectious for bloodborne pathogens).
Identify and use engineering controls. These are devices that isolate or remove the bloodborne-pathogens hazard from the workplace. They include sharps disposal containers, self-sheathing needles, and safer medical devices, such as sharps with engineered sharps injury protection and needleless systems.
Identify and ensure the use of work practice controls. These are practices that reduce the possibility of exposure by changing the way a task is performed, such as appropriate practices for handling and disposing of contaminated sharps, handling specimens, handling laundry, and cleaning contaminated surfaces and items.
Provide personal protective equipment, such as gloves, gowns, eye protection, and masks. Employers must clean, repair, and replace this equipment as needed. Provision, maintenance, repair and replacement are at no cost to the worker.
Make available hepatitis B vaccinations to all workers with occupational exposure. This vaccination must be offered after the worker has received the required bloodborne pathogens training and within 10 days of initial assignment to a job with occupational exposure.
Make available post-exposure evaluation and follow-up to any occupationally exposed worker who experiences an exposure incident. An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious material. This evaluation and follow-up must be at no cost to the worker and includes documenting the route(s) of exposure and the circumstances under which the exposure incident occurred; identifying and testing the source individual for HBV and HIV infectivity (if the source individual consents or the law does not require consent); collecting and testing the exposed worker’s blood, if the worker consents; offering post-exposure prophylaxis; offering counseling; and evaluating reported illnesses. The healthcare professional will provide a limited written opinion to the employer and all diagnoses must remain confidential.
Use labels and signs to communicate hazards. Warning labels must be affixed to containers of regulated waste; containers of contaminated reusable sharps; refrigerators and freezers containing blood or other potentially infectious material; other containers used to store, transport, or ship blood or other potentially infectious material; contaminated equipment that is being shipped or serviced; and bags or containers of contaminated laundry, except as provided in the standard. Facilities may use red bags or red containers instead of labels.
Provide information and training to workers. Employers must ensure that their workers receive regular training that covers all elements of the standard, including, but not limited to: information on bloodborne pathogens and diseases, methods used to control occupational exposure, hepatitis B vaccine, and medical evaluation and post-exposure follow-up procedures. Employers must offer this training on initial assignment, at least annually thereafter, and when new or modified tasks or procedures affect a worker’s occupational exposure.
Maintain worker medical and training records. The employer also must maintain a sharps injury log, unless it is exempt under Part 1904 – Recording and Reporting Occupational Injuries and Illnesses, in Title 29 of the Code of Federal Regulations.
Source: OSHA Fact Sheet, https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact01.pdf
Needlestick prevention: The product angle
Congress passed the Needlestick Safety and Prevention Act (Pub. L. 106-430) directing OSHA to revise its Bloodborne Pathogens Standard to establish in greater detail requirements that employers identify and make use of effective and safer medical devices. That revision was published on Jan. 18, 2001, and became effective April 18, 2001.
The revision to the OSHA standard did not impose new requirements for employers to protect workers from sharps injuries. But it did specify in greater detail the engineering controls, such as safer medical devices, that must be used to reduce or eliminate worker exposure.
Device selection plan
Employers must select devices that, based on reasonable judgment:
- Will not jeopardize patient or employee safety or be medically inadvisable.
- Will make an exposure incident involving a contaminated sharp less likely to occur.
Employers must solicit input from non-managerial employees responsible for direct patient care regarding the identification, evaluation, and selection of effective engineering controls, including safer medical devices.
Employers whose employees are occupationally exposed to blood or other potentially infectious materials, and who are required to maintain a log of occupational injuries and illnesses, must also maintain a sharps injury log. That log must be maintained in a manner that protects the privacy of employees. At a minimum, the log will contain the following:
- The type and brand of device involved in the incident.
- Location of the incident (e.g., department or work area).
- Description of the incident.
SUBHEAD: Engineering controls
Engineering controls include all control measures that isolate or remove a hazard from the workplace, such as sharps disposal containers and self-sheathing needles. The revision to the original Bloodborne Pathogens Standard specifies that “safer medical devices, such as sharps with engineered sharps injury protections and needleless systems,” constitute an effective engineering control, and must be used where feasible.
“Sharps with engineered sharps injury protection” includes non-needle sharps or needle devices containing built-in safety features that are used for collecting fluids or administering medications or other fluids, or other procedures involving the risk of sharps injury. This description covers a broad array of devices, including:
- Syringes with a sliding sheath that shields the attached needle after use.
- Needles that retract into a syringe after use.
- Shielded or retracting catheters.
- Intravenous medication delivery systems that use a catheter port with a needle housed in a protective covering.
“Needleless systems” is a term defined as devices that provide an alternative to needles for various procedures to reduce the risk of injury involving contaminated sharps. Examples include:
- IV medication systems that administer medication or fluids through a catheter port using non-needle connections.
- Jet injection systems, which deliver liquid medication beneath the skin or through a muscle.
Source: OSHA, April 2001, https://www.osha.gov/needlesticks/needlefact.html
Safe medical devices
Manufacturers of medical devices, in particular, sharps – continue to respond to the need for safe medical devices.
Terumo Medical Products’ safety hypo line offers a safety device that can be activated multiple ways – finger, thumb, hard surface – to accommodate nurse preference or current practices, says Bob Klock, director of sales and marketing. The hypo line reduces training and the likelihood of sticks with change in procedures.
Nurses may resist if they have to change current practices, or if administration makes it difficult to change, says Klock. “We try to minimize that.”
Even today, almost 17 years since the Needlestick Safety and Prevention Act was signed, many physician practices still resist the difference in price between conventional and safety products, says Klock. But that may be changing. “Larger groups…are mandating safety as they buy up practices. I feel that as more practices get bought up by IDNs and groups, there will be more usage.”
SUBHEAD: B Braun
Cheryl Wozniak, product director for vascular access at B. Braun Medical, believes healthcare providers have done a good job moving to needlestick-prevention devices, however, there is room for improvement in safety-engineered device selection.
Recent Global Healthcare Exchange (GHX) data shows that providers continue to use active safety devices – that is, those that require clinicians to activate the safety mechanism – about 66 percent of the time, while passive safety devices – those that engage automatically – are only used 34 percent of the time, Wozniak points out. “There needs to be a concerted effort for all healthcare organizations to use the safety engineered technology that does not require the clinician to activate the device’s safety feature,” but that engages automatically, she says.
Says Wozniak, the B. Braun Medical Introcan Safety® family of IV catheters with passive, automatic safety feature – the Introcan Safety 3 – is the only brand to offer one catheter with automatic needlestick protection and an option with multi-access blood control. Passive catheters are proven to be two times better than semi-automatic “push button” safety devices and three times better than a manually sliding shield., she points out, citing a 2010 article in Infection Control and Hospital Epidemiology. “With Introcan Safety 3 catheters, clinicians get the best of both worlds – automatic, passive needlestick and blood exposure protection.”