July 30, 1999

To Our Customers

Subject:   Cal/OSHA Bloodborne Pathogens Regulations (Section 5193)

Use of Needle Destruction Devices

Many of you have expressed some confusion regarding how needle destruction devices fit into the new Bloodborne Pathogens Regulations. Based on concerns expressed by board members responsible for approving these regulations, Cal/OSHA clarified their position on needle destruction units in their Final Statement of Reasons. The Final Statement of Reasons is a binding interpretation of the regulations by Cal/OSHA.

"Under [the Methods of Compliance] subsection, technology such as needle-destruction devices are authorized and encouraged provided they do not violate other, more specific provisions." [Final Statement of Reasons, Section 5193, Bloodborne Pathogens, page 10]

The new standard has specific provisions regarding education and training, device evaluation, recording of injuries and so forth. In other words, full compliance requires changing work practices in addition to use of newer technologies. This is one of the reasons we developed NICSx, our behavior based performance management system.

Of additional interest is that Cal/OSHA has told us that the mere purchase of engineering controls, including sharps with engineered sharps injury protection, does not automatically bring a facility into compliance. Regardless of the technology used, facilities must demonstrate by objective criteria that the chosen technology reduces the risk of accidental needlestick injuries. Again, this is why Biomedical Disposal offers a comprehensive approach to accidental needlesticks.

Michael W. Smith,
CEO and President
Biomedical Disposal, Inc.