
In recent years, the federal Occupational Safety and Health Administration and its state counterparts have been stepping up inspections for compliance with sharps safety and other issues at surgical facilities nationwide. Some of the resulting citations and fines have made headlines. How well do you know the agency's needlestick prevention regulations? Read over the following quiz to find out.
1. OSHA directs surgical facilities to develop a written blood and body fluid exposure control plan. Which of the following is not required for inclusion in the plan?
- A review of the exposure risks employees face on the job.
- Trials of manufacturers' latest safety devices.
- Documentation of physicians' opinions on retractable scalpels.
- Standardization of your surgical supply purchases.
Answer: d. The Bloodborne Pathogens Standard (tinyurl.com/4f8mcwb) is the rule of the road as far as sharps safety is concerned. But you may not be aware that you're ultimately responsible for developing an exposure control plan, or are resistant to it. The Centers for Medicare and Medicaid Services' Conditions For Coverage makes the plan mandatory, though, and "We've always done it this way, no one's ever been stuck" doesn't pass muster.
Besides government regulators, many accreditation agencies and professional organizations have issued guidelines on identifying sharps risks and implementing safer practices, based on the OSHA regulations. The Association of periOperative Registered Nurses' Sharps Safety Tool Kit compiles the necessary rules, references and forms all in one place. It'll save you hours of work.
2. How often should you review and update your exposure control plan?
- Updating is not required if no injuries are reported.
- Before each accreditation survey.
- Annually.
- Quarterly.
Answer: c. It's easy to fall into the complacent trap of drafting a plan, educating your staff and trialing a crop of safety-engineered devices one time, then losing sight of the safety requirements and issues and never giving them another moment's thought. Especially if your surgeons have been vocal in their opposition to safety scalpels. I'll grant them that: The earliest products didn't have the same weight in their hands as the traditional scalpels they depended on. It was more than a decade before a company delivered one that satisfied our surgeons. (As for blunt suture needles, I'm estimating another 3 to 5 years before there's something that really works for the mainstream.) But the safety environment is changing, as you'll note when you routinely revisit it.
3. True or false? The exposure control plan must include input from non-managerial staff members.

Answer: true. Patient care responsibilities carry a potential risk of sharps injuries and exposure to blood and body fluids, so you should consult staff representatives on these risk management details and decisions. There's a strong argument for putting staff members in charge of developing your exposure control plan. Think about it: Employee-driven practice evaluations and decisions have a better chance of fostering compliance.
4. True or false? If a safety-engineered version of a sharp exists, an employer is required to implement it, according to the federal government's needlestick safety and prevention standards.
Answer: false. The aim of federal regulations is to reduce the likelihood of injuries and exposures, but they depend on the reasonable judgments of those on the front lines of clinical care. No one type or brand of device is considered appropriate or effective for all specialties or circumstances. If a product doesn't meet users' safety or medical integrity standards, it might hurt more than it helps. OSHA and other inspectors are open to the idea that some facilities have rejected certain safety-engineered alternatives to traditional sharps. But evaluation and documentation are key. They want to see evidence that you routinely trial the available options until you and your surgeons and staff find one that you like. Justify your decisions with descriptions, signatures and dates.
5. True or false? Safety-engineered sharps are the only OSHA-sanctioned solution for preventing sharps injuries.
Answer: false. While engineering controls are a useful means of minimizing risk, sharps safety involves more than just switching out surgeons' traditional scalpels for redesigned alternatives. Work practice controls, such as the use of "neutral zone" passes and scalpel blade removers, also put safety into effect. Facilities that have undergone OSHA inspections report that surveyors have looked favorably on neutral zone passing, which eliminates hand-to-hand transfer of surgical instruments with a designated area in the sterile field, a kidney basin, a transfer tray or a magnetic pad. As an added bonus, it doesn't demand that surgeons give up the tools they're accustomed to using.
6. In a sharps injury log, an incident report should include all of the following details, except:
- the location of the employee's injury.
- whether a time out had been observed before surgery.
- the type and brand of device involved.
- a description of how the incident occurred.
Answer: b. Healthcare workers report about 385,000 sharps injuries a year. That's a huge number of nurses, techs, physician assistants and surgeons entering the healthcare system themselves at tremendous financial — and human — cost. Injury reports, medical testing, treatment, lost time, litigation, lasting complications that might include incurable illness or death — sharps injuries can be an expensive burden all around. In the unfortunate event that an incident should occur, a thoroughly documented injury log can be instructive in how to prevent another.
7. True or false? Failure to comply with the Bloodborne Pathogens Standard is the most frequently cited infraction in OSHA's surgical facility inspections.
Answer: true. The agency is taking sharps safety seriously. Between October 2012 and September 2013, the issue topped its list of citations given at "general medical and surgical hospital" sites. Out of 259 total citations in 81 inspections (resulting in $236,733 in fines), there were 65 bloodborne pathogen citations from 27 inspections (and $83,798 in fines).
8. True or false? Double-gloving is an effective sharps safety practice.
Answer: true. While OSHA doesn't mention it in its regulations, AORN has backed a study supporting double-gloving and the American College of Surgeons has recommended double-gloving for surgical personnel at the sterile field. The ACS's statement ranked the practice's effectiveness alongside the use of safety scalpels, blunt suture needles and neutral passing zones. The logic: If you're wearing 2 different colors of gloves, you'll have an automatic indicator if the outer glove has been breached. Also, the extra thickness of dual layers can shield hands against some contacts with sharp objects.
The risk is real. If you haven't witnessed or experienced a sharps injury incident, you might not appreciate its enormity. But that doesn't mean you shouldn't take steps toward prevention, in your employees' interest and that of the business you operate. So, one more question: Are you doing all you can to prevent sharps injuries in your facility?