Ask the Expert—Safety needles in small healthcare facilities

By: December 31st, 2008 Email This Post Print This Post

Q: Just where does it say that we have to use safety needles? We are opening a new medical practice and there is disagreement on this.

A: If the medical practice has employees who are at risk for exposure to bloodborne pathogens, then OSHA’s bloodborne pathogen standards applies, regardless of size, newness of the business, type of practice, etc.

This OSHA letter of interpretation,  “Bloodborne Pathogens Standard application to small healthcare facilities and the annual review of the Exposure Control Plan,” directly explains the requirement for a small healthcare facility,  such as a medical or dental practice, to follow the bloodborne pathogen standard.

It specially addresses the requirements to:

  • Provide safety-engineered sharp devices and needleless systems to employees
  • Review any new technological developments with regards to safety devices at least annually
  • Include input from non-managerial workers in the annual review of new safety devices

OSHA’s Medical & Dental Offices: A Guide to Compliance with OSHA Standards identifies the standards that frequently apply to small healthcare facilities. They are:

Of course the Quality America Basic Medical OSHA Compliance Manual Kit and the Medical Environment training videos on bloodborne pathogens and hazard communication will quickly get you started on OSHA compliance for a new office or identify compliance gaps with your current plan.


I have tried many times to get my doctors office to use safety blades and needles,unfortunatly it is like finding a needle in a haystack. The doctors just don’t want anything to do with them. Finally I have been able to get a team together to test different types of safety devices,in the same token they will not pass any of them because the standard states that as long as there is documentation showing they are trying to find a device that will work for their offices they really don’t have to choose one right away, Son now I’m left with employees having needle sticks, but the doctors saying well we just havn’t found the right one to use yet. Frustrating

By David LaHoda on March 2nd, 2009 at 4:24 pm

I think you or your doctors are misinterpreting the standard. Yes, you must show that you are trying out new safety devices, but “Limiting factors for implementing the use of engineering controls, i.e., safety scalpels, under the Bloodborne Pathogens standard” says you must document your decision. Compromising patient safety or market non-availability are two that OSHA recognizes. Your doctors don’t have carte blanche not to adopt safety devices just because their decision process takes forever.

Print out the letter and highlight this phrase: “Where exposures have been determined and where engineering controls are commercially available and feasible, they must be used.”

OSHA could interpret purposefully delaying the adoption of safety devices as a willful violation. So, highlight this portion of the letter:

“A willful or repeated violation may result in a penalty of up to $70,000; there is a minimum penalty of $5,000 for willful violations. Serious violations (where there is a substantial probability of death or serious physical harm) require a penalty of up to $7,000.”

Maybe that will get their attention, if the potential for sharps injuries to their employees won’t.


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