3. Element III: Engineering and Work Practice Controls

The use of engineering and work practice controls to reduce the opportunity for patient and healthcare worker exposure to potentially infectious material should be standard practice in all healthcare settings, not only in hospitals. Facilities are required to address and manage high-risk practices and procedures capable of causing healthcare-acquired infections (HAIs) from bloodborne pathogens.

[The information in this section is taken from the OSHA Bloodborne Pathogens Standard, 1910.1030.]

Engineering and work practice controls are intended to eliminate or minimize employee exposure. They must be examined and maintained or replaced on a regular schedule to ensure their effectiveness.

Engineering controls usually involve an object, such as sharps disposal containers, splash guards, self-sheathing needles, and safer medical devices that can isolate or remove the hazard from the workplace.

Work practice controls reduce the likelihood of exposure by altering the way a task is performed (e.g., prohibiting recapping of needles by a two-handed technique). Work practice controls tell how to do the job safely and should be described in written procedures.

Engineering and work practice controls are designed to reduce risk of percutaneous, mucous membrane/non-intact skin or parenteral exposures.

Percutaneous (through the skin) exposures can occur during handling, disassembly, disposal, and reprocessing of contaminated needles and other sharp objects, or via human bites, cuts, and abrasions. Activities that risk percutaneous exposures include manipulating contaminated needles and other sharp objects by hand, removing scalpel blades from holders, and removing needles from syringes.

Percutaneous exposures can also occur when performing procedures where there is poor visualization—such as blind suturing, non-dominant hand positioned opposed or next to a sharp and performing procedures where bone spicules or metal fragments are produced.

Mucous membrane/non-intact skin exposures occur when there is direct blood or body fluids contact with the eyes, nose, mouth, or other mucous membranes. This can occur via contact with contaminated hands, contact with open skin lesions/dermatitis, and from splashes or sprays of blood or body fluids (e.g., during irrigation or suctioning).

Parenteral refers to a route of transmission or administration that involves piercing mucous membranes or the skin barrier through such events as needlesticks, human bites, cuts, and abrasions. A parenteral exposure occurs because of injection with infectious material, which can occur during administration of parenteral medication, sharing of blood monitoring devices such as glucometers, hemoglobinometers, lancets, and lancet platforms/pens, and infusion of contaminated blood products or fluids.

3.1 Sharps Safety: Protecting Healthcare Workers

Approximately 385,000 sharps and needlestick injuries occur among the U.S. healthcare workforce each year, with nurses and physicians bearing the greatest burden of injury. Despite decades of regulation, these incidents are often underreported, creating potentially dangerous working environments (Krainev et al., 2025).

[Graphic Notice: Injectable Safety Cross-Section / Clear boundary fields. Neither portion of the injectable device may be reused under any circumstances. Source: CDC.]

Nurses are particularly at risk, as they sustain the greatest number of needlestick injuries. Studies have shown that as many as one-third of all sharps injuries in the hospital setting occur during sharps disposal. Common needle types involved include hypodermic needles (32%), suture needles (19%), winged steel needles (12%), IV catheter stylets (6%), and phlebotomy needles (3%) (OSHA, 2024).

Delaying or improperly disposing of sharps, leaving contaminated needles or sharp objects on counters or workspaces, or disposing of sharps in non-puncture-resistant receptacles can lead to sharps injuries. Recapping contaminated needles and other sharp objects using a two-handed technique is a common cause of injury.

Although hospitals account for the largest number of reported sharps injuries, they occur in other healthcare settings:

• clinical labs
• dental settings
• prehospital / EMS
• home health
• housekeeping, laundry, and waste management
• long-term care / nursing homes
• medical and nursing students

Data from the International Safety Center (ISC) reveals that needlestick injuries have not decreased over the past five years. Through the ISC's EPINet system, which collects data from 40 U.S. healthcare facilities, the number of needlestick injuries has remained alarmingly consistent through and beyond the COVID-19 pandemic (Umandap et al., 2024).

There has been an increased focus on removing or minimizing sharps hazards in healthcare settings through the development and use of engineering controls and safe work practices (Garus-Pakowska et al., 2022). Safety-engineered devices are designed with features such as shields, mechanisms that automatically retract, or blunt-tip features to isolate the hazard from the workplace (Serafin et al., 2023).

[Graphic Notice: Sharps with Safety Features Exposed (left) and Covered (right). Source: CDC.]

A comprehensive sharps injury prevention program includes measures to handle needles and other sharp devices in a manner that will prevent injury to the user and to others who may encounter the device during or after a procedure. Key elements include:

• safe disposal of used sharp instruments in an approved, puncture-resistant sharps container
• safer medical devices that feature safety protections to prevent percutaneous injuries
• involvement of frontline, non-managerial healthcare personnel in the selection and evaluation of safer devices (Garus-Pakowska et al., 2022)

3.2 Work Practice Controls

The following safety protocols reflect current, evidence-based practices regarding the handling of contaminated sharps and Other Potentially Infectious Materials (OPIM).

3.2.1 Sharps Handling and Disposal

Prohibition of manual manipulation: Contaminated needles and other contaminated sharps must not be bent, recapped, or removed unless the employer demonstrates that there is no alternative or that the action is required by a specific medical procedure.

Safety techniques: Manipulation must be accomplished using a mechanical device or a one-handed "scoop" technique to prevent needlestick injuries.

Shearing and breaking: Shearing or breaking of contaminated needles is strictly prohibited.

As soon as possible after use, contaminated reusable sharps must be placed in appropriate containers until properly reprocessed. These containers must be:

• puncture-resistant
• labeled or color-coded in accordance with OSHA standards
• leakproof on the sides and bottom
• maintained in accordance with OSHA requirements for reusable sharps

[Graphic Notice: Examples of FDA-cleared sharps disposal containers made from rigid plastic and marked with a line that indicates when the container should be considered full, which means it’s time to dispose of the container. Source: FDA, 2021, April 28. URL: https://www.fda.gov/medical-devices/safely-using-sharps-needles-and-syringes-home-work-and-travel/sharps-disposal-containers]

3.2.2 Work Area Restrictions and Hygiene

Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are strictly prohibited in work areas where there is a reasonable likelihood of occupational exposure to blood or OPIM. Food and drink must not be stored in refrigerators, freezers, shelves, cabinets, or on countertops/bench tops where blood or OPIM are present.

Facilities may designate specific, hazard-free zones (kept clear of body fluids, specimens, and gloves) where beverages are permitted.

3.2.3 Procedure and Specimen Protocols

All procedures involving blood or OPIM must be performed in such a manner as to minimize splashing, spraying, spattering, and the generation of droplets. Mouth pipetting or suctioning of blood or OPIM is prohibited.

Specimens of blood or OPIM must be placed in a container that prevents leakage during collection, handling, processing, storage, transport, or shipping. The container must be labeled or color-coded according to OSHA guidelines.

When a facility utilizes Standard Precautions in the handling of all specimens, the labeling or color-coding of specimens is not necessary, provided the containers are recognizable as containing specimens. Labeling or color-coding is required when such specimens or containers leave the facility.

3.2.4 General Practices for the Workplace

• Use proper hand hygiene.
• Use proper procedures for cleaning of blood and bodily fluid spills.
• Practice proper handling and disposal of blood and bodily fluids.
• Select, don, doff, and dispose of PPE as trained.
• Protect work surfaces in direct proximity to patient procedure treatment areas.
• Prevent percutaneous exposures by avoiding unnecessary use of needles and other sharp objects.
• Use care in the handling and disposing of needles and other sharp objects.

3.3 Evaluation/Surveillance of Exposure Incidents

Employers must identify those at risk for exposure and what devices cause exposure. All sharp devices can cause injury and disease transmission if not used and disposed of properly. For example, hollow-bore needles have a higher disease transmission risk, while butterfly-type IV catheters, devices with recoil action, and blood glucose monitoring devices (lancet platforms/pens) have a higher injury rate.