OSHA Hazard Information Bulletins
September 21, 1995
MEMORANDUM FOR: |
REGIONAL ADMINISTRATORS |
THROUGH: |
STEPHEN MALLINGER, Acting Director
Directorate of Technical Support |
FROM: |
|
SUBJECT: |
Hazard Information Bulletin(1): Potential for
Occupational Exposure to Bloodborne Pathogens From
Cleaning Needles Used in Allergy Testing Procedures |
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FOOTNOTE(1) The Directorate of Technical Support issues Hazard Information
Bulletins (HIB) in accordance with OSHA Instruction CPL 2.65 to provide
relevant information regarding unrecognized or misunderstood health hazards,
inadequacies of materials, devices, techniques, and safety engineering
controls. HIBs are initiated based on information provided by the field
staff, studies, and concerns expressed by safety and health professionals,
employers, and the public. Information is complied based on a thorough
evacuation of available facts, and in coordination with the appropriate
parties.
The purpose of this safety and health Hazard Information Bulletin is to
alert field personnel to the possible safety and health risks which may arise
with the practice of a procedure performed in allergy testing known as "prick
and wipe" or "scratch and wipe". The 29 CFR 1910.1030, Occupational Exposure
to Bloodborne Pathogens standard applies where occupational exposure to blood
or other potentially infectious materials (OPIM) can be reasonably
anticipated [2(a); 2(b)]. It is estimated that numerous physicians,
allergists, dermatologists, pediatricians, family practitioners, and their
employees use this traditional allergy testing method.
The "prick & wipe" type allergy testing procedure provides many
opportunities for inadvertent occupational exposure of the health care worker
(HCW) to a percutaneous exposure with a contaminated sharp. As described by
practicing allergists, the procedure requires the HCW to introduce allergenic
extract or control solutions into the skin by piercing or scratching the skin
with a device, such as a hypodermic or bifurcated needle. Bleeding at the
site may occur during the application of the test solutions. If only one
device per patient is used to apply multiple allergenic extract solutions
(50-60 applications may be performed on a single patient), the cleaning of
the sharp to remove the previously introduced test solution and any body
fluids is required. Most typically this is accomplished using a
two-handed technique. This practice of cleaning the sharps device has
the potential for a bloodborne pathogens exposure incident.
In general, 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens
standard requires the employer to use engineering and work practice controls
as the primary method to eliminate or minimize employee exposure [29 CFR
1910.1030, (d)(2)(i)]. Traditional procedure has been to clean the
sharps device with one hand holding the testing device and the other
hand holding the cleaning apparatus, e.g., cotton ball soaked in isopropyl
alcohol (See illustration). Alternative controls to using this two-handed
technique are currently available to the employer at little or no additional
expense. Examples of these controls include the following:
1) The use of engineering controls, e.g., disposable, one-time,
single-allergen use, skin test devices, currently available from several
manufacturers. These should not be re-used but discarded after the
allergenic extract solution is applied.
2) Altering the task itself to accommodate safer work practice.
Although its cleaning and re-use is not preferred, a single-handed technique
of cleaning the sharp can be implemented which reduces the employee's
potential of direct percutaneous contact with a contaminated sharp.
a) Place the cleaning solution-soaked apparatus on a rigid
surface, e.g., metal tray. Using a one-handed technique, pass the
contaminated sharp through the apparatus using a holding
device.
b) Hold the cleaning-solution soaked apparatus with an
instrument, e.g., forceps or hemostat, in one hand. Pass the contaminated
sharp through the apparatus using a holding device.
In general, personal protective equipment (PPE), i.e., gloves, is not
necessary when performing allergy skin testing as long as hand contact with
blood or OPIM is not reasonably anticipated. However, where occupational
exposure remains, PPE shall also be used [29 CFR 1910.1030, (d)(3)(i)].
Notedly however, most medical use gloves will not prevent an employee needle
puncture. The engineering and work practice controls suggested above would
be effective in preventing such an exposure.
OSHA recommends that the engineering and work practice controls implemented
in cleaning the needles used for allergy testing procedures be carefully
evaluated to determine their effectiveness in eliminating or minimizing
potential occupational exposure to bloodborne pathogens through the
percutaneous route.
Please distribute this bulletin to all Area Offices, State Plan States,
Consultation Projects and appropriate local labor and industry associations.
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