On 11 May, new regulations regarding the use of ‘safer sharps’ need enforcing. Shaun Howe asks if you and your employers up to scratch?
The Health and Safety Executive (HSE) has produced new guidance for employers and employees that encompass aspects of the European Council Directive 2010/32/EU (the Sharps Directive) not currently present in UK Law. These new regulations apply to those employers whose primary function is to provide healthcare and also applies to those that may be contracted by such employers, locums for example. The following is taken from the HSE document.
The management of sharps risk is led by the preventative measures laid out in the Control of Substances Hazardous to Health (COSHH) but these new regulations require employers consider additional risk management strategies.
Avoid the unnecessary use of sharps – regulation 5(1) (a) The regulation acknowledges that certain objects (eg: needles) are required for medical procedures but suggests that, when reviewed, organisations have found staff using medical sharps for uses for which they were never intended. With this in mind, it requires employers ensure such sharps are used only for their designed use. The regulations suggest that where it is not reasonably practicable to avoid the use of medical sharps, the regulations require employers to use ‘safer sharps’.
Use safer sharps (incorporating protection mechanisms) – regulation 5(1) (b) Under this regulation, an employer must substitute unprotected sharps with those that incorporate features or mechanisms that reduce or eliminate the risk of accidental injury. There are already syringes/needles that integrate a slide or cover that protects the user. It has to be remembered that safer sharps do not remove all risk as injury can occur accidentally during a procedure (eg: the patient moves unexpectedly). The regulations suggest end users should be involved during the selection of safer sharps to ensure risk is reduced.
Preventing the recapping of needles – regulation 5 (1) (c) Any operator who uses medical sharps appreciates that injury can occur when the needle has been used and then uses one hand to hold the cap and the other to guide the needle. The regulation requires that no needles are recapped unless a risk assessment has identified that recapping is required to prevent a risk. There are only limited examples given where recapping is acceptable and, even then, it must be carried out using safety devices (needle blocks) to only allow one-handed recapping.
Place secure containers and instructions for safe disposal of medical sharps close to the work area – regulation 5 (1) (d)
The regulations require that healthcare facilities place clearly marked and secure containers close to the operator (so sharps can be dropped straight into the container) and that instructions for use are placed in this area. Dental practices that keep sharps containers in cupboards may have to reconsider their current protocols.
Information and training
The information provided to employees – regulation 6 This regulation requires employers must provide information to employees in the following areas:
• The risks of injuries involving medical sharps
• Relevant legal duties on employers and workers
• Good practice in preventing injury
• The benefits and drawbacks of vaccination
• The support available to an injured person from their employer
Employee training – regulation 6 (4)
The sharps regulations require employers to provide training to employees that should cover the following areas:
• The correct use of safer sharps
• Safe use and disposal of sharps
• What to do in the event of sharps injury
• The employer’s arrangements for health surveillance (and other procedures)
Arrangements in the event of injury
Injured employee’s duty to notify their employer of a sharps accident – regulation 8 Any employee who receives a sharps injury must inform their employer as soon as is practicable. The employer must have suitable arrangements to allow notification in a timely manner.
Recording and investigating the incident – regulation 7 (1) Employers are required to record incidents of sharps injury when reported, regardless of who reports this. The employer must investigate the injury and the injured person must provide any necessary information to allow this. The information gathered should include the name of the injured, the nature of the injury, the location where the incident occurred and should identify the type of sharp that caused the injury. The report should also identify at what stage of the procedure the injury occurred and the severity of the injury. The investigation needs to be proportionate to the nature of the injury; for example an injury from a clean (sterile) sharp may just require listing the nature/location of the injury and details of first aid whereas injuries from contaminated sharps will require more vigorous investigation and analysis.
Investigations exist to allow scrutiny of an employer’s existing preventative control measures are adequate or need strengthening. Where necessary, other agencies expertise may be required (occupational health, infection control teams etc.) to support such investigations. Where there may have been exposure to blood borne virus or other significant infection, establishing the infection status of the source patient (if known) should be sought. By sharing this information with treating medical professionals the unnecessary use of prophylaxis measures (anti-virals) can be avoided.
There are some drastic and some subtle changes that employers need to enshrine into their current practice policies and protocols to ensure compliance with these new regulations. Yet it must not be forgotten that the employee also has their own responsibilities under these regulations. If in any doubt, further advice may be sought from your local HSE.
When changing to safer sharps, consider…
• The new device must not compromise patient care
• The reliability of the device
• The operator can retain appropriate control over the procedure
• Ease of use
• If the safety mechanism design is suitable for the application?
Shaun Howe trained in the Army in 1993. Shaun likes to write and is well-known for his outspoken views on regulation and all matters dental. He is one of three DCP local advisers to Dental Protection, an active member of the FGDP in the West Midlands regional group, a trained practice appraiser and a moderator on www.hygienist.co.uk.