Needlestick Prevention Act:
EpiPen Use
A
“new generation” EpiPen is available which uses safety engineering
for needle stick prevention. Since
this safety engineered version is now available, it must be the one
that is purchased and used to be in compliance with the Needlestick
Prevention Act and other OSHA laws.
When ordering or reordering EpiPens, services should specifically
request the “new generation” EpiPen and not accept order shipments
containing the old version of the EpiPen as it is no longer in
compliance with OSHA laws.
OSHA's
Bloodborne Pathogens Standard applies to all ambulance service and first
responder service providers. This
is the law that mandates the Bloodborne Pathogen Exposure Control Plan
for each service.
The subsequent Needlestick Prevention Act mandates that if there is a
safety device available, it must be used unless there is a patient
safety issue that overrides the employee safety issue.
Safety controls or “devices” include sharps
disposal containers, self-sheathing needles, safer medical devices, such
as sharps with engineered sharps injury protections and needleless
systems.
The requirement to implement safer medical
devices is not new. If you have not already evaluated and implemented
appropriate and available engineering controls, you must do so during
the mandated annual review of your services Bloodborne Exposure Control
Plan. During your annual
review of devices, you must inquire about new or prospective safer
options and document this fact in your written Exposure Control Plan.
When evaluation is complete, devices should be implemented
promptly after appropriate education and training on the use of any new
device.
Safety equipment must be available at all times. If for some
reason an engineering control is not available (due to supply shortages,
back orders, shipping delays, etc.), this must be documented in your
Exposure Control Plan. You would then be responsible to implement the
chosen control(s) as soon as it becomes available and adjust your
exposure control plan to illustrate such. In the meantime, work practice
controls must be used and, if occupational exposure still remains,
personal protective equipment must also be used.
There
are several resources available for employers and employees with regard
to occupational exposures to blood and OPIM. Please see the following
websites:
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