Scenario: Instead of disposing of the single-use sharp device into a regulated sharps container immediately upon completion of the tattoo procedure, it is not uncommon for many tattoo artists to re-sterilize the device in order to break off the needle configuration so that they may re-use the bar itself.
This procedure requires the “breaking, bending, or shearing” of a sharp, which is expressly prohibited by OSHA.
The justification for this practice is generally related to lower cost, when the cost of a single needle bar averages between $.01 and $.30 cents. It is our opinion that the reprocessing of the used needle configuration denotes reusability and terminal sterilization is not ensured.
Question: How does the Bloodborne Pathogens Standard apply to this practice?
Response: The scope and application of the Bloodborne Pathogens Standard is dependent on reasonably anticipated occupational exposure to blood and other potentially infectious materials (OPIM). Since tattooing and piercing generate blood, workers in this industry would fall under the scope of the standard.
Proper implementation of a bloodborne pathogens exposure control plan, infection control procedures, and standard precautions protect not only workers from potential exposure, but clients, as well. The standard requires the use of engineering and work practice controls to eliminate or minimize employee exposure to blood and OPIM. When occupational exposure remains after the institution of these controls, personal protective equipment must also be used.
Understandably, engineering controls for tattoo needles may not be commercially available., therefore the use of proper and safe work practices carries a higher level of importance. Safe work practices would include the immediate disposal of contaminated needles into an appropriate regulated waste container. Bending, recapping, breaking, and) or shearing contaminated needles required additional manual manipulation, which poses a greater risk of injury. If safer needle devices do become available, an employer must evaluate, select, and implement appropriate devices, based on employee feedback.
Therefore, it is OSHA’s position that in the tattooing and piercing industry, proper work practices must be followed, including the immediate disposal and proper containerization of single-use contaminated needles. An employer must also ensure the use of appropriate personal protective equipment (e.g., gloves, gowns) depending on the types of exposures that may be anticipated (e.g., splashes, splatters, drips). Again, employees with occupational exposure to blood, identified by an employer’s exposure determination (29 CFR 1910.1030 (c)(2)) must be afforded full coverage of the standard, including, but not limited to: the hepatitis B virus vaccination, post-exposure evaluation and follow-up, and appropriate housekeeping and decontamination procedures.
