OSHA UPDATE 12/1/02

VHCA

In a September 12, 2002 letter of interpretation, the Occupational Safety and Health Administration (OSHA) clarified that the use of needle destruction devices (NDDs) contribute to a safer workplace, but does not alone put an employer in compliance with the bloodborne pathogens standard.  Noting that an NDD, like a sharps disposal container, is an engineering control for the point of disposal and may be beneficial in reducing exposure to downstream workers, it provides no protection while an employee is using the needle or prior to placing the needle in the device.  According to OSHA, the most effective way of removing the hazard of a contaminated needle is to eliminate the needle completely by converting to a needleless system; and if this is not possible, removal of the hazard as soon as possible after contamination is required, which is best accomplished by using a sharp with engineered sharps injury protection (SESIP).

OSHA categorizes NDDs, and conventional sharps containers, as engineering controls for the disposal of contaminated needles.  According to OSHA, the use of an NDD alone will not be sufficient to meet the standards requirements where a different or an additional control, such as a needleless system or a SESIP appropriate for the procedure, is commercially available and feasible and will reduce exposure to a lower level.