The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
#212 Preventing Sharps Injuries: The Role of Engineering Controls
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Did you know that evaluating safer sharps devices is require as part of OSHA Bloodborne Pathogens training? The Divas provide information on what you must include in training, along with the what, why and how of engineering controls and engineered Sharps Injury Protections (ESIP).
Resources:
- Needlestick Safety and Prevention Act https://bit.ly/4mt3Pfb
- Healthcare Purchasing News - Two Decades Later, Are We Safer? Revisiting Sharps Injury Prevention in U.S. Healthcare https://bit.ly/47PvEd4
- CDC Workbook for Designing, Implementing & Evaluating a Sharps Injury Prevention Program https://bit.ly/4mYzcxX
- Annual Needlestick and Sharps Injury Evaluation form https://www.thecompliancedivas.com/resources
- CDC Sharps Evaluation Worksheet https://www.thecompliancedivas.com/resources
- Examples of Sharps Safety Devices for Dentistry https://www.thecompliancedivas.com/resources
Welcome.
SPEAKER_01I'm Leslie Cannum. I'm Mary Gavoni.
SPEAKER_00I'm Linda Harvey. I'm Olivia Juan, and together we are the Compliance Divas.
SPEAKER_01Welcome to the Compliance Divas podcast. This is Leslie Cannum and I will be the moderator today, along with Mary Gavoni. We have a very special podcast on engineered sharps with sharps injury protection. Did you know that you have to evaluate safety syringes? At the Compliance Divas, we bring clarity and simplicity to compliance, and we bring podcasts to you with information that you can use for your staff meetings. So you probably are familiar with the Bloodborne Pathogen Standard. If you work in dentistry, this was enacted in 1991, and it ensures that workers understand how to protect themselves from exposure to bloodborne pathogens, not only initially when someone is hired with a practice annually, and then whenever there are new or modified tasks that affect exposure to blood-borne pathogens. But there was a revision that was made, and Congress finds that the following is true: that numerous workers who are occupationally exposed to blood-borne pathogens have contracted fatal and other serious viruses and diseases, including hepatitis B, hepatitis C, and HIV. So in 1991, the bloodborne pathogen standard promulgated, requiring us to have training on the various different exposure diseases such as hepatitis and HIV. Now, the reason for the blood-borne pathogen standard is that it significantly reduces the risk that dental workers will contract a blood-borne pathogen disease in the course of their work. Nevertheless, occupational exposure to blood-borne pathogens from accidental sharps injuries in health care continues to be a serious problem. Now, in March of 2000, the Centers for Disease Control and Prevention estimated that more than 380,000 percutaneous injuries from contaminated sharps occur annually among healthcare workers in the United States. And they estimated that healthcare workers in hospital settings that the risks are even higher, that there were 600,000 to 800,000 needle stick and other percutaneous injuries that occur. So, since publication of the Bloodborne Pathogen Standard, there's been a substantial increase in the assortment of effective engineering controls available for employees to use. And now there's a large body of research and data that concerns the effectiveness of newer engineering controls, including safer medical devices. So, with that all being said, numerous studies demonstrate that the use of safer medical devices such as needless systems and sharps with engineered sharps injury protections, when they are part of an overall blood-borne pathogen risk reduction program, can be extremely effective in reducing accidental sharps and injuries. So, in drawing this all together, training and education in the use of safer medical devices and safer work practices are significant elements in the involvement of making sure that team members understand how to reduce Sharps injuries. So, as new Sharp devices and safer Sharp devices are introduced into the work setting, dental workers, as well as other healthcare workers, are required by OSHA to evaluate these devices. Now, it doesn't state anywhere in the regulations that you have to use these devices, but you simply have to evaluate these devices.
SPEAKER_00Thanks, Leslie. Just a little side note before we get into all that. I know that early on in the advent of this needle safety standard back in 2001, there were a number of companies that introduced safety syringes. And there was a study, I believe, published in the ADA journal that showed that there were more sharps injuries from recapping using those types of syringes than there were with traditional one-handed scoop techniques or using a recapper device. So many dental professionals kind of ran for the hills and said, no, we're not going to do that. But they forgot that they're still required, as you said, to do that evaluation. And as you said, Leslie, and I think that's really important, you're not required to use them, but you're required to have an awareness. You're required to know that needle sticks and also cuts from scalpel blades are potential injuries. And because they're percutaneous, where they could introduce blood or blood and saliva into the tissue, it's a little more significant infection risk. So let's take a look at OSHA's definition of engineering controls. What the bloodborne pathogen standard says that we must use engineering controls to minimize or eliminate employee exposure to bloodborne pathogens. The controls are physical or mechanical systems that isolate or remove hazards from the workplace. And they list examples: sharps disposal containers, so we don't have contaminated needles in the trash where somebody could get poked. Safer medical devices, like, as Leslie mentioned, needless systems that gain vascular access without the use of a needle, either some other type of a blunt-ended device that does the venipuncture or it's a pressurized system, those types of needless systems, not as common in dentistry. And then sharps with engineered sharps injury protections and things that automatically either retract or shield the needles. And I want to, again, throw in scalpel blades into that category because we have a number of devices that have retractable scalpel blades. So we don't want to forget about those types of injuries. And what we've done at the Compliance Divas is developed a list of safer devices that can be downloaded from the show notes. And it's got product examples. We are not evaluating the products, we're just making you aware of what's available and the web link to go to the manufacturer's website to look at those. And you can use that list when you have your annual needle stick sharp safety evaluation and say, okay, we looked at these devices, and then you can decide whether it makes sense to try one or not. And I would base that on the types of injuries that you have happen in your practice and how often those injuries are happening. Because you'd have a really hard time making a case to OSHA or in a workers' comp claim, for example, if you had a lot of needle stick injuries and you didn't do something as an employer or the safety manager to intervene, follow a different protocol, get a different device. Because remember, that general duty clause has the obligation of employers to provide a workplace safe from known hazards. So we have that list of devices, and we also have developed a checklist for you to go through for evaluating those devices and document them. And that should be part of your annual training documentation for compliance with OSHA and the Bloodborne Pathogen Standard.
SPEAKER_01Mary, thank you so much for the explanation. And it is an awesome idea to download this checklist and the products that we are uh putting out to our audiences so that you know where to go with what devices do I evaluate? What do I ask my dental supplier for? And then how do I conduct that evaluation? So this is a great resource. And you know, it's funny, Mary, I was on the CDC website looking for an evaluation form. I think I spent 20 minutes going from page to page to page. I found a document that was 168 pages that was on evaluating Sharp's injury prevention program. And I know most of our listeners are very busy. So this is going to be a great resource for them to have at their fingertips. And I want to remind everyone that this is required as part of your annual OSHA training. So please don't forget to review Engineered Sharps, to have documentation that you have reviewed it, have everyone sign the documentation that's on the review committee and hint that should be every clinical team member, whether they give injections or simply clear syringes from a treatment room or break down the needle from the syringe at the end of the appointment. And remember, there's something else besides engineering controls that should be discussed, and that's work practice controls. If we choose not to use one of the various different devices for safer syringes or scalpels or any of the recapping devices that are available on the market today, then we must be very skilled at using a one-handed scoop technique. And we also want to remind our clinicians if they have to bend needles for any procedure, whether it's, I know my dad's an endodontist and he would occasionally bend his needles for either access or irrigation, that the clinician should be the one to straighten that needle back up, maybe with a cotton plier or a force, that the clinician should be the one to bend that needle back straight to so it can be recapped and to recap that needle themselves. And that can be done, of course, with a cotton plier or a needle holder. And that way we don't have the potential of a bent needle going through the cap of a syringe and potentially causing an exposure incident. And of course, we can rely on some of our dental assistant, dental hygienist and dentist training to retract with a mouth mirror instead of a finger and make sure that we're doing those, those are called good work practice controls. Watch where we're reaching when we reach for instruments on a treatment tray and just make sure that make sure that we're paying attention to what we're doing. So as we go through, I just want to um ask Mary again: what is the best way to document that we've done this sharps evaluation among our team members at our OSHA training? And how do we prove to an OSHA auditor that that we are doing everything we can to reduce needle sticks and accidents with sharps?
SPEAKER_00Well, Leslie, we have a form for that. We've developed a form that actually is like an agenda for the annual sharp safety evaluation meeting where you go through and document whether or not you've had any sharps injuries and what type of injuries, and whether there was PPE being worn or a safety device being used, and whether it might have been prevented. So we kind of walk you through that process with this evaluation form, and there's a section for everybody to sign so you've documented it, and then you can attach any evaluation forms that you've used for specific devices. And I always tell people pay attention to things like dental products reports. Dental economics always has new product introductions in their publication as well. And you can clip that product information, maybe photocopy it, attach it to your documentation of types of devices that you've used that are kind of time-saving things, or you can do obviously an internet search to try to find things. But if you look in the dental products reports, for example, you're gonna get a little more information right from the manufacturer. So those are some good hints. One other thing I so agree with you, Leslie, on what you said about the clinician being the one to uh bend a needle back to get it in position to be able to recap it. I also, and I used to teach dental assisting the wonderful pass the syringe technique where the dental assistant loosens the cap on the needle, puts the syringe in the doctor's hands, pulls the cap back, and doctor injects. But not a good idea for the doctor to pass that uncapped needle back to the dental assistant. That is the recipe for a needle stick. It's now a contaminated needle. Not a good idea. I recommend to my practices that the doctor or the hygienist, so whoever whoever the clinician is, that they do the recapping. They either have a recapping device on their tray or they do a one-handed scoop technique so that we don't pass a contaminated needle to someone else.
SPEAKER_01That is such great advice, Mary. And it, you know, there's also a patient safety issue to pass a syringe needle over a patient's face. We remember Jen Morone, who was the victim of a needle, a syringe needle that was um dropped. Jen Marone, who was the victim of a dropped anesthetic syringe where the needle poked on her eye and caused her to have permanent eye damage. So patient safety, not passing syringes and or other sharp devices over a patient's face, uh, being aware of what you're doing when you're working with sharp items. Also, we want to make sure that everyone remembers that when you break down a syringe, don't bend or break the needle for the purpose of disposal. So many times I've seen the syringe needle, it's not quite off of the hub. And for some reason, the person removing the needle is compelled to bend it at the short end, not the long end of the needle, but the part that goes into the anesthetic carpole. And I asked someone, why do you do that? And they said, well, you know, then it's not going to be used again. And I thought, why in the world will we use a syringe needle a second time? You're just creating a new opportunity to have a sharps injury. Take the needle directly off of the syringe, put it in the sharps container. And again, one more thing not to bend. Watched my dad do it many times when he got to a point where he was not going to use an endophile anymore, he would bend it instead of so that would indicate to his assistant not to reprocess that endophile. And uh as time went on, we realized it was better just to put that thing straight into the sharp's container.
SPEAKER_00And speaking of which, if a practice is doing any type of sedation where they're using disposable syringes to inject medications, disposable syringes are not to be recapped. They should be put directly into the sharps container after the injection is completed. We do not recap disposable syringes.
SPEAKER_01You know, Mary, we have several different podcasts. The complaints, Divas, we have over 200 podcasts, and we have several that are devoted to sharps injuries and how to conduct that type of training. Also, we talk about sharps containers. So I would encourage our listeners to go back, take a look through our various different podcasts, and use these podcasts as a basis for your annual OSHA training. And with that, we're going to close this podcast today. We hope that you've enjoyed the information and that you will utilize that to help make your team safer at work. At the Compliance Divas, we bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please submit your questions to support at thecompliancedivas.com. Also look for the resources that we mentioned today in the show notes. And we would absolutely love it if you would give us a review. Let us know how you like the compliance divas podcast, and if you'd like to continue to have podcasts on these subjects, such as dental office safety or other subjects that are important in dentistry. Thank you for joining us.