APIC argues against Cal-OSHA regulations

Given the diverse and complex nature of health care settings and procedures, "a one-size-fits-all" regulation for needle safety devices would be a mistake, warns the Association for Professionals in Infection Control and Epidemiology (APIC) in Washington, DC.

APIC submitted comments on the first draft of a proposed needle safety regulation the California Occupational Safety and Health Administration (Cal-OSHA) and was in the process of reviewing and commenting on the second draft when this issue went to press.

"We urge you to reconsider the inclusion of any provision that would restrict health care professionals from determining the best practices for their individual facilities," state comments submitted by APIC president Fran Slater, RN, MBA, CIC.

"APIC has concerns that efficacy of devices would be difficult to define and quantify. We believe that a more appropriate approach would be for facilities to evaluate the circumstances surrounding their needlestick injuries, to ascertain if, when, and where it would be beneficial and appropriate to implement the use of safe needle devices."

The APIC comments on the issue of needle safety and regulation may preview the group's position should national OSHA consider similarly amending the bloodborne pathogen standard. While underscoring its commitment to preventing the spread of infection in health care facilities, APIC urged the agency to give adequate consideration to all aspects of a complex issue before promulgating a standard. Key points in the APIC comments on the proposed Cal-OSHA regulation are summarized as follows:

· The dynamic nature of infectious disease poses special challenges for all health care facilities. These challenges are based on varying patient populations and community health issues that are unique to each facility. Due to the complex differences among facilities and even within facilities (from department to department), it is not appropriate to impose regulations that are "one-size-fits-all."

· Safer needle products have a legitimate and appropriate place in some health care procedures, but not in all. For example, resheathing needles are ideal for paramedics who work in areas where sharps containers are not readily available, while emergency room personnel often find such devices cumbersome and time-consuming in potentially life-threatening situations.

· Regulating the use of certain types of devices, without due regard to the unique needs of individual health care departments may very well prove to be detrimental rather than beneficial. In fact, there have been reports in the medical literature documenting the occurrence of bloodstream infections in patients, resulting from the misuse of safe needle devices.

· Keys to the successful adoption of a safety device include: establishing a multidisciplinary task force including the user, defining the needs for each institution by department, developing criteria for the selection of the product, identifying a methodology for evaluation of the product; and analyzing the cost benefits of the product. In addition to these necessary elements, it is also important to implement education and behavior modification programs. These are elements that OSHA cannot adequately address.

· Regulations do not necessarily ensure successful adoption and use of safe needle devices because traditional devices may continued to be favored by workers over the safety devices. Safe needle devices are most readily accepted when potential users perceive a need for them, feel that they are at risk for injury, and have input into the device selection process.