EU Directive on sharp injuries: be prepared

The recent EU Directive on prevention from sharp injuries will require all healthcare organisations to introduce measures to prevent needlestick injuries (NSIs) to their staff, and reduce the incidence and prevalence of the 400,000 occupational injuries to NHS staff each year. Recognising the need to improve healthcare worker safety, reduce the cost of treating injured workers, and avoid expensive legal actions, a number of public and private healthcare organisations across Europe have already converted to the use of safety-engineered devices, in advance of the impending legislation. An environment where NSI’s can be prevented, but an area that is often missed or not considered is the operating department. Over a third of incidents occurring between 2000-2007 in the ward or in A&E (43% and 37% respectively), and around 20% in intensive care and in operating theatres (22% and 20% respectively) were preventable with proper adherence to universal precautions and safe disposal of clinical waste.1 The UK HPA Centre for Infections scheme report 914 NSIs with hollow-bore needles being the greatest risk accounting for 68% of all percutaneous exposures between 2000-2007.1 In a study of 98 UK surgeons in a large district general hospital,244% anonymously admitted to having a needlestick injury. The study concluded that the incidence of such injuries was likely to be under-reported, particularly in the surgical sector. The European Directive objectives can be summarised simply as:

• To achieve the safest possible working environment.
• To prevent workers’ injuries caused by all medical sharps. 
• To protect workers at risk. 
• To set up an integrated approach establishing policies in risk assessment, risk prevention, training, information, awareness raising and monitoring. 
• To put in place response and follow up procedures. 

In preparation for the implementation of the Directive into legislation it is thought that the Health & Safety Executive (HSE) will embark on a programme of consultation before deciding how the Directive should be implemented into health and safety legislation. Of course, it may decide that to reduce any further burden on employers it would be simpler to add the directive to existing legislation with supporting information and guidance. As an example, the COSHH legislation requires employers to evaluate the risks and select reasonably practicable control measures by the adoption of the hierarchical approach: Because of the nature of exposures to blood borne viruses (BBV) in the healthcare environment it may not be reasonably practicable to prevent exposure to BBV’s. As such healthcare employers are required to control the risk by the application of protection measures relevant and appropriate to the occupational activity and risks. These could include consideration of the design and use of appropriate work processes, systems and engineering controls together with the use of suitable work equipment and that where adequate control of exposure cannot be achieved by other means, the provision of suitable personal protective equipment (PPE) in addition to other risk prevention measures. Failure of employers to adopt these principles can result in adverse effects for the healthcare employee and employer. Any healthcare employer who needs reminding of the penalties of non compliance with legislative control measures should consider the case of Alison Dugmore,3 where as the result of a breach of the Regulation 7 of the COSHH regulations, which imposes an absolute duty on an employer to ensure that exposure of his employees to substances hazardous to health is either prevented or controlled, resulted in Dugmore being exposed to Natural Rubber Latex. The resulting action by Dugmore and her legal team concluded in a successful damages claim in excess of £300,000. Every healthcare employee would support the notion that every effort should be made to avoid accidental exposure to blood and body fluid through the use of safe systems of work. To prepare, employers should ask themselves the following questions: