When I do a mock OSHA inspection, I always look at the sharps containers. I check to make sure discarded sharps items have not exceeded the fill line. If the sharps container is clear, I can easily see what’s inside. Otherwise, I try to look down into the container.
I look for scalpels that do not have sheaths over the blades, non-retractable lancets, and needles that are non-safety engineered.
On a recent inspection, I knew that the practice I was inspecting was using all safety devices, so what I found was very surprising!
When I inspected the first exam room, the sharps container held all safety needles. BUT, the safety feature had not been engaged on the majority of the needles.
I waited to question what I saw until I looked at other exam rooms. Every needle looked the same. This particular safety device was the type that you used your thumb to click the safety feature down over the needle.
The office manager was as puzzled as I was. We questioned every employee and they claimed to have properly used the needles by engaging the safety features.
We decided to inform the physician that we had a problem with someone in the office. When I reviewed my findings with her, the physician sheepishly said, “I had no idea I was supposed to click that thing on the needle.”
I asked her if she realized what the intent of the safety device was, and she replied that she thought she was exempt from using it as intended.
My inspection turned into an educational session with the physician. I informed her that as an employee of her practice, she must comply with proper use of all safety devices. We also held a demonstration class for the physician and the entire staff on the proper technique for using all safety devices in the office.
Remember, you may use a non-safety needle to draw up medication and switch to a safety needle to give the injection. In this case, you should document this practice in your Exposure Control Plan along with your policy for how it is disposed and capped, so there is no misunderstanding should an OSHA inspector peer into your sharps container.