Epi-pen information

Posted on: Fri, 05/14/2004 - 9:50am
NutlessMOM's picture
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Joined: 09/17/2003 - 09:00

The school nurse informed me today that OSHA has changed the rules on the use of NEEDLES at the school. The needles has to have an retractable needle. To my knowledge, there are no epi-pens made this way. The nurse said that I have to get documentation from the pharmacy stating this as a fact. Has anyone else ever heard of this new OSHA rule?

Posted on: Fri, 05/14/2004 - 2:10pm
ElleMo's picture
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Joined: 06/19/2003 - 09:00

Info is here:
[url="http://www.osha.gov/SLTC/etools/hospital/hazards/sharps/sharps.html#Safer"]http://www.osha.gov/SLTC/etools/hospital/hazards/sharps/sharps.html#Safer[/url]
It doesn't specificy schools, but I am assuming this is what the nurse is refering to.
[This message has been edited by ElleMo (edited May 15, 2004).]

Posted on: Fri, 05/14/2004 - 2:40pm
Nutternomore's picture
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Joined: 08/02/2002 - 09:00

Nutless Mom,
Well, that was certainly an "interesting" way for her to present it to you!
I'm not a nurse, but here's my interpretation about what's going on here, based on some quick 'n' dirty web research...
In 2001, the Needlestick Safety and Prevention Act was put into place. While this Act mandated that OSHA include several new provisions into its Bloodborne Pathogens standard, it did not change, but simply amplified, the importance of and requirements for the implementation of engineering controls (e.g., Sharps with Engineered Sharps Injury Protection) in healthcare and similar settings.
The following Q&A from [url="http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24012"]http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=240 12[/url]
discusses this issue pretty well.
[i]2. When do these facilities have to have "engineered control devices" safety needles in their facilities, what date?
OSHA's Bloodborne Pathogens Standard, which became effective in March 1992, requires that every employer perform a workplace exposure determination in order to identify hazards and implement proper controls. Although the requirement to implement safer medical devices is not new, the revised standard (2001) further clarifies what is meant by "engineering controls;" it adds language to the definition section of the original 1991 standard that reflects the development over the last decade of safer medical devices.
The standard requires, "(e)ngineering and work practice controls shall be used to eliminate or minimize employee exposure." Engineering controls are defined as, "controls (e.g., sharps disposal container, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove a hazard from the workplace." Examples of engineering controls most applicable in healthcare are needleless intravenous systems, retractable needles, and other sharps with engineered sharps injury protection (SESIPs).
According to CPL 2-2.44D [CPL 2-2.69], Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, where exposures to blood and other potentially infectious materials (OPIM) are reasonably anticipated and engineering controls will reduce employee exposure either by removing, eliminating, or isolating the hazard, they must be used. Consequently, you should already have safer devices in place. If you have not already evaluated and implemented appropriate and available engineering controls (safer medical devices), you must do so immediately.
(Correction 3/15/02)
The exposure determination, as well as the evaluation, implementation, and use of the engineering controls must be documented in the employer's Exposure Control Plan. The plan must be updated at least annually and must reflect changes in job tasks and procedures, and advances in technology. [/i]
Now, you're probably aware that each state also has an OSHA group. Found this document from TOSHA (you're from TN, correct?) that also discusses Sharps Injury Prevention [url="http://www.state.tn.us/labor-wfd/sharpslist.pdf"]http://www.state.tn.us/labor-wfd/sharpslist.pdf[/url]
So, what I simply think is happening here is that the nurse is evaluating "engineering controls" to see whether it is possible to go to a retractable needle. The letter you get from your pharmacy (or from Dey for that matter) would provide the audit trail that it was investigated, but that no one makes an Epi-Pen in the US that has a retractable needle.
IMHO, it was inappropriate for her to state that it is a requirement that a retractable needle must be used. Can't find any evidence that her statement is factual. Perhaps she should provide you with documentation to back up her statement [img]http://uumor.pair.com/nutalle2/peanutallergy/wink.gif[/img]
Hopefully, some of the nurses on this board can comment on this situation to see if I've got it right...
[This message has been edited by Nutternomore (edited May 15, 2004).]

Posted on: Sat, 05/15/2004 - 1:13am
Anonymous's picture
Anonymous (not verified)

Nutless Mom, Dey is the only manufacturer of the Epi-pen and it is not retractable (obviously). So, what can be done?
Did the nurse say why she was presenting this information to you?
Are the concerned about what to do with the sharp once they administer the Epi at school if they had to?
I know that the last time we administered the Epi, and it was not at school, I had the used Epi in my purse and I gave it to the E.R. doctor and he disposed of it.
There is no retractable form of Epi-pen. I'm just wondering what it is the nurse is trying to say really.
Best wishes! [img]http://uumor.pair.com/nutalle2/peanutallergy/smile.gif[/img]
------------------

Posted on: Sat, 05/15/2004 - 2:46am
NutlessMOM's picture
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Joined: 09/17/2003 - 09:00

THANKS to all of you that responded! I have printed off everything that you stated and I will investigate the web sites and I am sure I will print more material from there. Yes, I am in TN. To be honest, I feel some of this is retaliation because I applied for a 504 for both of my Peanut Allergy children yesterday. The nurse told me that the principle and herself did not want me to file for a 504 and they did not personally think that they qualified but of course, they do qualify.
Again thanks!!!!!!!!
Kim [img]http://uumor.pair.com/nutalle2/peanutallergy/smile.gif[/img]

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