Best Practice: OSHA's Position on the Reuse of Blood Collection Tube Holders

On October 15, 2003, the US Occupational Safety and Health Administration (OSHA) posted a Safety and Health Information Bulletin (SHIB) to clarify the OSHA position on reusing tube holders during blood collection procedures. The purpose of the SHIB was to reiterate OSHA's earlier statement that the best practice to prevent needlestick injuries following phlebotomy procedures is the use of a sharp with engineered sharps injury protection (SESIP)(e.g. safety needle) attached to the blood tube holder and the immediate disposal of the entire unit after each patient's blood is drawn.

Q. What are the steps that need to be taken to evaluate my current work practices versus the latest OSHA SHIB?
The OSHA SHIB provides a step-by-step Evaluation Toolbox for a facility to follow (see below).

Q. When does the OSHA SHIB go into effect?
The OSHA SHIB is simply a clarification of the OSHA Bloodborne Pathogens Standard [29 CFR 1910.1030 (d) (2) (vii) (A)]. The standard prohibits the removal of a contaminated needle from a medical device. Prohibition of needle removal is addressed in the 1991 and 2001 standards, the OSHA compliance directive (CPL 2-2.69), as well as a 2002 letter of interpretation. Therefore, there is no grace period.

Q. Does the OSHA SHIB apply to all phlebotomy devices?
Yes, it applies to any needle device that has an unprotected back end needle, including the following safety-engineered needle devices: multiple sample needles, winged blood collection sets and luer adapters.

Q. Are there any situations in which it is still acceptable to remove a needle from a blood collection device?
According to the OSHA SHIB and OSHA's 2001 Compliance Directive (CPL 2-2.69), there may be situations that necessitate using a syringe to draw blood. The blood collected into the syringe would then need to be transferred into a tube before disposing of the contaminated syringe. In these situations, a syringe with an engineered sharps injury prevention feature and safe work practices should be used whenever possible. Transfer of the blood from the syringe to the test tube must be done using a needleless blood transfer device. The BD Vacutainer® Blood Transfer Device (reference number 364880) can help to satisfy this OSHA requirement.

Q. What holder products does BD offer that are intended for single use?

Q. Will BD have enough of the One Use Holders when demand for these products increases?
Yes. BD is in the process of notifying hospitals, medical suppliers and other facilities that it has an ample supply of the BD Vacutainer® One Use Holder to meet the changing needs of it's customers.

Q. Will there be any other changes to the needle holder products that BD is currently offering?
The BD Vacutainer® Standard Yellow Needle Holders (reference numbers 364888 and 364983) have been discontinued (not available after 1/31/04) and are no longer available as a stand-alone holder for use with blood collection devices. They will still be used as a component for other safety products, such as the BD Vacutainer® Blood Transfer Device, BD Vacutainer® Direct Draw Adapter, and BD Vacutainer® Luer-Lok™ Access Device.

Q. What happens if a facility does not comply with OSHA regulations?
As with any OSHA rule or regulation, non-compliance may result in the issuance of citations by an OSHA compliance officer after the completion of a site inspection. It is the responsibility of each facility to evaluate their work practices, implement appropriate engineering controls, and institute all other applicable elements of exposure control in order to achieve compliance with current OSHA rules and regulations.

To view the OSHA SHIB in its entirety, visit the OSHA website.

For more information on the BD Vacutainer® One Use Holder, contact your local BD Diagnostics, Preanalytical Systems Sales Consultant or contact our BD Global Technical Services Department by telephone at 1.800.631.0174 (within USA) or by email.

OSHA SHIB Evaluation Toolbox

• Employers must first evaluate, select, and use appropriate engineering controls (e.g., sharps with engineered sharps injury protection), which includes single-use blood tube holders with sharps with engineered sharps injury protection (SESIP) attached.
• The use of engineering and work practice controls provide the highest degree of control in order to eliminate potential injuries after performing blood draws. Disposing of blood tube holders with contaminated needles attached after the activation of the safety feature affords the greatest hazard control.
• In very rare situations needle removal is acceptable.
  • If the employer can demonstrate that no feasible alternative to needle removal is available (e.g. inability to purchase single-use blood tube holders due to a supply shortage of these devices),
  • If the removal is necessary for a specific medical or dental procedure.
• In these rare cases, the employer must ensure that the contaminated needle is protected by a SESIP prior to disposal. In addition, the employer must ensure that a proper sharps disposal container is located in the immediate area of sharps use and is easily accessible to employees. This information must be clearly detailed and documented in the employer's Exposure Control Plan.
• If it is necessary to draw blood with a syringe, a syringe with engineered sharps injury protection must be used in which the protected needle is removed using safe work practices, and transfer of blood from the syringe to the tube must be done using a needleless blood transfer device.

To view the OSHA SHIB in its entirety, visit the OSHA website.

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