OSHA estimates that almost 600,000 needlesticks occur each year among our nation's 5.6 million healthcare workers. In response to these statistics, OSHA published a Compliance Directive (CPL 2-2.44D, November 5, 1999) clarifying the Bloodborne Pathogens standard as it pertains to safety needles. The 78-page document directs OSHA inspectors to cite medical facilities that have not evaluated sharps containers, needles, IV connectors, etc. to be sure that the safest products possible are in use.

OSHA refers to these products as "engineering controls" and emphasizes that readily-available advances in medical technology must be used in employers' safety programs. In fact, the current Bloodborne Pathogens standard states that "engineering controls are examined and maintained or replaced on a regular schedule to ensure their effectiveness". Rather than expecting employers to automatically institute the most sophisticated engineering controls (e.g., needleless IV connectors, self-sheathing needles), OSHA maintains that it is the employer's responsibility to evaluate the effectiveness of existing products and to review the feasibility of instituting safer ones.

Even though only one state, California, currently mandates switching to safe sharps products, the new directive makes it crystal clear that OSHA expects medical employers in every state to evaluate and consider switching to safety products. Depending on the results of the evaluation, you may either switch to new, safer products or keep using existing products. OSHA's directive does not state exactly under what circumstances you MUST switch or under what circumstances you may decide to retain current products.

The entire Directive can be accessed from OSHA's home page @ Copies are also available from OSHA's Publications Office @ 202-693-1888.




  1. Make a list of all sharp products used in your workplace. A Sharps List is enclosed that you may use for this purpose. Locate alternative "safe sharps" products that would substitute for your current sharp products. Start with problematic areas, i.e., areas where needlesticks have occurred.

  2. Evaluate those alternatives to current sharp products. A sample Sharps Evaluation Procedure and several Sharps Evaluation Forms are enclosed.

  3. Amend your OSHA manual to include the safety devices you select, if applicable.

  4. Complete a Sharps Injury Log whenever a needlestick occurs to keep track of the types of devices that are most problematic.



    List Brand(s) Currently In Use


    e.g. Needlesticks


    Sharps Containers





    Injection Equipment





    Blood Collection Equipment




    IV Medicine Delivery Systems And Insertion Equipment








    Surgical Scalpels




    Suture Needles











                ______________________                      _____________________

    OSHA Safety Officer                                                           Date


    This "Sharps Evaluation" procedure helps to determine if a particular "safe" sharp will minimize occupational exposure to needlesticks and, therefore, should be implemented in your facility. Each workplace is different in terms of the types of procedures performed, the types of patients seen, and the habits and preferences of employees. Therefore, this Sharps Evaluation process enables you to evaluate the effectiveness of existing sharp devices and to review the feasibility of instituting more advanced, possibly safer, sharps devices.

    For OSHA Safety Officers

    1. Determine which products are to be evaluated and provide at least four or more test samples for each individual evaluating the product. (Each evaluator should have enough samples to disassemble and examine the design thoroughly.) Employees chosen for the Sharps Evaluation Procedure should currently use a similar category of product in your workplace.
    2. Provide visual instructions and demonstrate the proper use of each device. Be sure testers can evaluate products in a simulated patient environment; provide training dummies, if needed (e.g., injection pads).
    3. Review the instructions and rating system with each evaluator.
    4. Require each evaluator to complete an Evaluation Form.

    5. Review responses on Evaluation Forms; make conclusions, recommendations.


    For Evaluators 

    1. Re-enact all steps of intended or possible procedures performed with the device.

    2. Attempt to misuse the device and circumvent or disable the safety feature.

    3. Answer each question on the Evaluation Form, including any short answer sections at the end. If you do not understand a question, please write comments directly on the sheets.