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November 12, 2003
Assistant Secretary John Henshaw
Occupational Safety And Health Administration
Department Of Labor
200 Constitution Avenue
Washington, D.C. 20210
Dear Assistant Secretary Henshaw:
I write to applaud OSHA's action in citing Montefiore Medical Center
for violations of the OSHA Bloodborne Pathogens Standard. Our non-profit
organization promotes prevention of medical sharps injuries, and
OSHA's action regarding Montefiore Medical Center sends a powerful
message on behalf of needlestick safety.
NAPPSI's principal focus is on primary prevention -- approaches
and technologies that reduce or even eliminate the need to use a
sharp for a medical procedure. NAPPSI also supports the use of secondary
prevention where primary prevention is not possible. Examples of
primary prevention measures in the Montefiore case are needleless
IV access devices and sutureless securement devices for securing
tubes and catheters. Secondary prevention measures would include
safety blood drawing and flushing needles; safety injection needles;
and safety scalpels.
Our organization advocates needlestick-safety measures for all
healthcare workers. A recent focus of ours has been protecting the
nation's interns and residents from needlesticks related to suturing
-- which are the No. 1 needlestick risk faced by interns and residents,
according to International Healthcare Worker Safety Center. Among
primary-prevention measures to prevent suture needlestick injuries
are surgical glues and sutureless securement devices for catheters
and tubes. Secondary-prevention measures include safety surgical
instruments for suturing.
Please convey NAPPSI's thanks to the dedicated OSHA staff whose
enforcement efforts at Montefiore and other healthcare institutions
are essential to the well-being of America's healthcare workers
and the patients for whom they care.
Sincerely yours,
Steve Bierman, M.D.
President
National Alliance for the Primary Prevention of Sharps Injuries
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