Sharps, Biohazard Waste and the Needlestick Safety Act

The Needlestick Safety and Prevention Act and Exposure Controls

Healthcare environments present daily risks of contact with bloodborne pathogens. To address these hazards directly, the Needlestick Safety and Prevention Act was enacted to reduce occupational exposure to bloodborne pathogens among healthcare workers. This legislation prompted the Occupational Safety and Health Administration (OSHA) to revise its Bloodborne Pathogens Standard, establishing clearer obligations for facilities to safeguard their teams during clinical procedures like blood collection.

Under these revised standards, employers are required to implement engineering controls. Engineering controls are defined as devices or equipment that isolate or remove a bloodborne pathogen hazard from the workplace. A primary example in phlebotomy is the use of sharps with engineered sharps injury protections (SESIP). Alongside engineering controls, healthcare teams must use work practice controls. Work practice controls reduce exposure risk by altering the manner in which a healthcare task is performed, ensuring that safer behaviors accompany safe equipment.

Frontline phlebotomists have an essential voice in maintaining workplace safety. Employers are required to solicit input from non-managerial frontline healthcare workers when evaluating and selecting safety-engineered devices. Furthermore, employers must review and update their written exposure control plan at least annually to reflect ongoing improvements in safety technology and procedures.

When an accidental exposure does take place, facilities must track it systematically. Employers subject to OSHA's sharps injury log requirement must record each percutaneous injury from a contaminated sharp, including the device type and brand, the work area or department, and how the injury occurred, while protecting employee confidentiality. This ongoing documentation helps safety committees identify patterns and prevent future injuries.