OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 23, 2003

The Honorable Randy "Duke" Cunningham
U.S. House of Representatives
Washington, DC 20515-0551

Dear Congressman Cunningham:

This is in response to your letter of November 21, in which you expressed your concern about the needlestick hazard which healthcare professionals face when securing catheters with sutures. The Occupational Safety and Health Administration (OSHA) shares your concern about the hazards of needlesticks and has demonstrated this by revising the Bloodborne Pathogens Standard (29 CFR 1910.1030) in response to the Needlestick Safety and Prevention Act of 2000.

The revised Bloodborne Pathogens Standard requires employers whose employees have occupational exposure to blood and other potentially infectious materials (OPIM) to implement appropriate and available safer medical devices designed to eliminate or minimize occupational exposure. Employers must solicit the input of frontline employees in the identification, evaluation, and selection of safer devices. Sutureless catheter securement devices are one type of the safer devices that may be evaluated in this required process. According to OSHA's traditional adherence to a hierarchy of controls and basic industrial hygiene practice, engineering and work practice controls must be instituted as the primary means of eliminating or minimizing employee exposure. Suture needles used to secure catheters on a patient constitute a hazard regulated by the standard. OSHA recognizes that eliminating the need to use suture needles decreases the risk of a potentially hazardous procedure. The use of sutureless securement devices is one method an employer can use to eliminate this potential needlestick hazard.

During an employer's annual review of his Exposure Control Plan (ECP), he must evaluate the practices and processes used in the facility and address the methods by which exposure to blood and OPIM will be controlled (29 CFR 1910.1030(c)). The ECP must also address implementation and evaluation of proper engineering and work practice controls, personal protective equipment, and employee training. If an employer determines that an alternative to using sutures to secure catheters is appropriate and feasible, he must implement it. If, however, an employer determines that no alternative is feasible (e.g., it compromises patient safety or the medical procedure), then he must document that in his ECP and re-evaluate alternative engineering controls or substitution methods the following year.

In your letter you ask that OSHA consider issuing an information bulletin regarding needlestick hazards associated with suture securement of catheters. We try to be very cautious about taking any action that might be perceived to be an endorsement of aspecific product. For this reason, OSHA does not provide a list of safer devices or recommend specific types of devices. Apparently, there is currently only one manufacturer who produces a catheter securement device that reduces or eliminates the need for suturing. We will continue to evaluate whether an information bulletin is appropriate as resources permit. We are sharing information about this device with our compliance assistance staff to ensure that they are aware of this device as an option to employers.

You also ask that OSHA provide a link from its website to the website of the National Alliance for the Primary Prevention of Sharps Injuries (NAPPSI). OSHA is actively looking for useful web sites to link to that provide additional, unbiased, reliable information to our customers. We are currently reviewing the information on the NAPPSI site to see if it meets our criteria.

OSHA's commitment to reduce the hazards of needlesticks to healthcare workers is an important part of the agency's mandate to protect worker safety and health. Thank you for your interest in this issue and for your thoughtful letter. If you have any further questions, please feel free to contact the Office of Occupational Health Nursing at 202-693-2120.


John L. Henshaw
Assistant Secretary