Your Employee Had a Needlestick Exposure – What Do You Do?

What do you do when an employee has a needlestick exposure?

STEP 1 – ARRANGE FOR AN IMMEDIATE MEDICAL EVALUATION

• The EMPLOYER is required to offer confidential medical evaluation, laboratory testing, and follow-up care at no expense to the employee.
• Early intervention is essential for effectively managing potential illness and preventing the transmission of bloodborne infections.
• NOTE: The employee who participates in post-exposure evaluation has the option to withhold consent for HIV testing. In this instance, the employer must ensure that the blood sample is preserved for at least 90 days if they change their mind.

STEP 2 – DOCUMENT EVERYTHING!

• Employers are required to evaluate the circumstances surrounding the exposure.
• employee injury report, witness statements, etc.

STEP 3 – REPORT THE INCIDENT (if required)

• Reporting to OSHA or other respective state agencies identifies the source individual to reduce or stop further transmission.
• Any employer who is required to maintain a log of occupational injuries and illnesses under OSHA’s Recordkeeping regulation (29 CFR Part 1904) is also required to maintain a sharps injury log. Employers must record all work-related needlestick injuries contaminated with another person’s blood or other potentially infectious material (as defined by 29 CFR 1910.1030) on the OSHA 300 Log.
• If an employer is exempt from the OSHA recordkeeping rule, the employer does not have to maintain a sharps log.

STEP 4 – TEST THE SOURCE PATIENT

• If the status of the source individual is unknown, the employer is required to test them as soon as possible, provided the individual consents or identification is feasible.
• If they do not consent, the employer must establish that legally required consent cannot be obtained or is prohibited by state or local law.
• State or local law may allow testing without the source individual’s consent.
• When the source individual is already known to be infected with Hep B or HIV, testing for the source individual’s status need not be repeated.

STEP 5 – PROVIDE RESULTS

• The employer must obtain and provide the employee with a copy of the healthcare professional’s written opinion within 15 days.
  • According to OSHA’s standard 1910.1030(f)(5), the written opinion should ONLY include:
    • Was hepatitis B vaccination recommended?
    • Did the employee receive the vaccination?
    • Did the healthcare provider inform the employee of the results and any medical conditions resulting from exposure that require further evaluation or treatment?
    • Any other findings should not be included in the written report
• When medically indicated, post-exposure prophylaxis must be offered.
• Counseling must include implications of the exposure, infection status, and how to protect others.
• The employee must be informed of laws and regulations regarding disclosing the source’s identity and infectious status.
• Note: In accordance with OSHA’s Standard for Access to Employee Exposure and Medical Records, 29 CFR 1910.1020, employee medical records must be accessible to both the employee and OSHA representatives.