The consultation on the HSE review of impending sharps safety regulation following EU Council Directive 2010/32/EU is now closed.

Currently, IOSH is trumpeting its own submission that proposes, as Blenkharn Environmental and others have also done, an extension of the formal protection afforded to include protection to those outside the healthcare sector who might be exposed to, or injured by, sharps.

That stance cannot be criticised. However sympathetic this stance may be, the thrust of their argument misses important detail. There is little value in providing safety sharps as far as sharps injury reduction from discarded drug litter is concerned. It will still be discarded, and safety devices, if provided, are unlikely to be activated. The issue of fully automatic devices to diabetics and IV drug uses is unthinkable. Sad as it is, it will simply be too expensive.

The real necessity is to comprehend the need for defined protocols for sharps injury management, for use in every A&E department. This will stop Local Authorities suggesting that residents stuck by a needle should write in for a free leaflet or make an appointment with their GP, and will stop those working in the commercial sector being referred to an off-site occupational health provider that might result in a week-long delay for attention. That is simply not good enough.

It is imperative that those presenting to A&E should not be fobbed off as time wasters with nothing more that a trivial injury. The potential impact far outweighs the mechanical aspect of the injury received.

2010/32/EU goes much further that requiring safety sharps. It requires also urgent access to specialist Infectious Diseases teams for assessment of the need for and management of post-exposure prophylaxis and careful follow-up. That should apply to all and the DoH, supported by HSE, must ensure that is available for all sharps injury “victims”.

To assess the scale of these problems, and ensure effective monitoring by HSE, it would be advantageous that sharps injury was incorporated specifically into RIDDOR. Mandatory reporting would give HSE some data upon which to act, since their current plan is to puss and blow, but with no plan to develop mechanisms for monitoring of compliance with the new sharps regulation. Cost is no barrier, as the new FFI seems to be an effective money spinner than neutralises the excuse of budget constraint on questions about the activities of HSE.

Lastly, science would fail if it did not flag the importance, yet again, of splash inoculation. This can be an important mechanism for the transmission of bloodborne virus infection. Splashes onto damaged skin, a previous cut or damage due to eczema, psoriasis or chronic dermatitis and splashes to teh eyes of mouth can and do transmit infection. It would be advantageous to include these events also into the upcoming legislation since such events are almost always due to some defect in safe working practice. This is the exact scenario in which HSE would be expected to intervene, but by excluding its incorporation to the proposed legislation and insisting on a mandatory notification scheme it is difficult to envisage a way in which HSE might properly manage this new legislation.