Ask the expert: Pardon my exclamation, but DON’T REMOVE DIRTY NEEDLES!

By: November 11th, 2010 Email This Post Print This Post

Q: It has been standard procedure in our small medical practice to remove contaminated needles from the syringes to save space in the sharps container. I am concerned that this will significantly increase my potential risk of a “dirty” stick. Is this a legal practice? What can I do to reduce my risks, without losing my job?

A: This is absolutely illegal. Let me put it another way…THIS IS ABSOLUTELY ILLEGAL!

It says so in the Bloodborne Pathogens standard section (d)(2)(vii): “Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed…”

Please inform your employer that this violation of the OSHA standard could not only injure staff members but also cost it as much as $7,000 as a serious fine, as classified by OSHA.

If your employer continues this practice, it could become a willful fine, which ups the ante to $70,000.

Since you just saved your practice $70,000, a smart employer would thank you rather than fire you, which in itself could be a violation of the federal Whistleblower protection section of the OSH Act, which “prohibits any person from discharging or in any manner retaliating against any employee because the employee has exercised rights under the Act.”

Agree or disagree? Let me know in the comment section below.

Comments

Wow – better to save lives than save needles, don’t you agree?

By Judy Ruggeri on November 14th, 2010 at 11:35 am

In dental practices we do not use a disposable syringe. The needle is removed and placed in the sharps container. Is this llegal?

By David LaHoda on November 14th, 2010 at 9:12 pm

No, it is not legal unless it is a medical necessity. Dental settings are subject to the same OSHA requirements as medical practices. Why would anyone think otherwise?

Is it a requirement for syringes to be disposed of as medical waste? (if not used with a needle?)

By David LaHoda on November 15th, 2010 at 11:12 am

The answer on disposal of syringes without needles attached depends on your state regulated medical waste (RMW) laws. Some states say it is OK to dispose of syringes with no visible trace of blood or OPIM as solid waste while other states say to dispose as as RMW.

For state-specific RMW laws, see the Practice Greenhealth State-by-State Regulated Medical Waste Resource Locator.

The question arose at my place of employment as to whether or not your ‘exclamation’ applies if one is using ‘safety’ needles. Is it acceptable to remove such needles from the syringe?

By David LaHoda on November 17th, 2010 at 3:08 pm

According to section (d)(2)(vii) pf the Bloodborne Pathogens standard, OSHA does not want any contaminated needles “bent, recapped, or removed,” unless there is a medical necessity. And that also means documenting it in your exposure control plan.

I’m curious, under what circumstances would you need to remove a safety needle?

Maybe I wasn’t clear. I meant removing any needle from the syringe including removing a safety needle from the syringe itself prior to disposal. In the interest of saving space in the sharps containers.

By David LaHoda on November 17th, 2010 at 3:21 pm

No, you were perfectly clear. Contaminated needles are not to be removed–certainly not in the interest of saving space in the sharps disposal container.

OSHA wants to eliminate any work practice that adds to the likelihood of exposure, and the extra handling of contaminated needles definitely increases the risk of exposure.

Thank you. That was my understanding as well. I wanted to clarify for everyone interested.

By Judy Ruggeri on November 18th, 2010 at 7:46 pm

In response to your Nov 14th posting. Please refer to paragraph (d)(2)(vii)”Certain circumstances may exist in which recapping, bending, or removing needles is necessary… If one were to continue to read further the section a,b,c, you could see that dental offices may be able to recap and remove the sheath and needle as a unit to dispose leaving the metal syringe.

By David LaHoda on November 19th, 2010 at 9:29 am

Judy:

Yes, that is correct if what you describe—and there are three important “ifs,” here—is a medical necessity, if there are no other safer alternatives as evidenced by the annual sharps evaluation, and if documented in the exposure control plan.

In support of this advice, Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens states:

“If the employer claims that no alternative to bending, recapping, or removing contaminated needles is feasible or that such action is required by a specific medical procedure, the compliance officer should review the exposure control plan for a written justification supported by reliable evidence. This justification must state the basis for the employer’s determination that no alternative is feasible or must specify that a particular medical procedure requires, for example, the bending of the needle and the use of forceps to accomplish this.”

I’m assuming this does not include the removal of “Sharps with engineered sharps injury protections ” from syringes? The sending of syringes with attached sharps, safe or not, to a clinical lab for testing is not advised.

This issue always seems to be a dilema. It is not safe to directly transfer blood from a syringe into a blood collection tube. BD, Smiths Medical and others all make safety transfer devices for syringe blood draws. First, the safety needle must be removed from the syringe inorder to use the transfer.

Once we switch to using transfer devices (about 10 years ago) we saw a 50% decrease in needle sticks related to syringe draws. We have this documented in our procedure as the safest way to perform a syringe draw and we have our own data to justify removing the needle.

By David LaHoda on November 24th, 2010 at 8:49 am

Did you see my follow-up post: Ask the expert: OK, we don’t remove regular dirty needles, but what about safety needles?

Sending a syringe with the contaminated safety needle attached to a lab is indeed a bad idea, but so is removing the needle.

“The practice of removing the needle from a used blood-drawing/phlebotomy device is rarely, if ever, required by a medical procedure,” says OSHA’s Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens.

Find a blood transfer devices that allows you to send the sample to the lab without removing the contaminated needle. The International Sharps Injury Prevention Society (ISIPS) is a good source.

When commercially available you must use such devices or show with documentation that it compromises patient safety.

The ISIPS site lists the blood transfer devices that require removal of the needle. These are made by Smiths Medical, BD, and Greiner and are in wide circulation. I looked for an OSHA interpretation letter but failed to find one that addresses these. I will check with the vendors. Remains a dilema.

 

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