Is Our Facility Required to Use Engineered Safety Devices?

Looking for more information on using engineered safety devices? We get a lot of questions at TMC about the OSHA Bloodborne Pathogens (BBP) standard requirement to use engineering controls, specifically sharps with engineered sharps protection often referred to as safety devices. Here are some specifics and resources you might find helpful if you are looking to implement a specific type of safety device.

Engineering controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace. Sharps with engineered sharps injury protections are a subset of engineering controls. They are a non-needle sharp or a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident.

The excerpts below are taken from the Revision to OSHA’s Bloodborne Pathogens Standard – Technical Background and Summary. It specifically addresses the Needlestick Safety and Prevention Act and the changes it required to the BBP standard. (

Changes to the Exposure Control Plan
Employer must:

take into account innovations in medical procedure and technological developments that reduce the risk of exposure (e.g., newly available medical devices designed to reduce needlesticks); and

document consideration and use of appropriate, commercially-available, and effective safer devices (e.g., describe the devices identified as candidates for use, the method(s) used to evaluate those devices, and justification for the eventual selection).

The document goes on to allow for the following considerations in adoption of a safety devices: No one medical device is considered appropriate or effective for all circumstances. Employers must select devices that, based on reasonable judgment:

will not jeopardize patient or employee safety or be medically inadvisable; and

will make an exposure incident involving a contaminated sharp less likely to occur.

Employee Input Employers must solicit input from non-managerial employees responsible for direct patient care regarding the identification, evaluation, and selection of effective engineering controls, including safer medical devices. Documentation of employee input Employers are required to document, in the Exposure Control Plan, how they received input from employees.

This obligation can be met by:

Listing the employees involved and describing the process by which input was requested; or

Presenting other documentation, including references to the minutes of meetings, copies of documents used to request employee participation, or records of responses received from employees.

Bottom line, if there is a safety device available and it will not jeopardize patient or employee safety or be medically inadvisable, the device should be implemented for use during patient care. But, how would you identify which devices are appropriate for use? There are engineering controls on the market for needles, scalpels, IV/port access devices, and blood draw equipment. If you are utilizing any of these sharps and have not implemented a safety device, please contact your medical supply/device distributor for samples to use during the evaluation phase.

Your TMC consultant will help you walk through this process if they work with you in your practice. Additionally, you may find the following websites and articles helpful.

If have not implemented safety devices, now is the time to begin the process. There is a wealth of data about the effectiveness of these devices to reduce sharps injuries which are a real health risk to healthcare providers.