sharps-needlestick-management

name	sharps-needlestick-management
description	Produces a consultant-grade sharps-injury prevention package and exposure-control plan for a named healthcare service, driven by the engineering-control-first hierarchy. Use this skill whenever a user asks to prevent needlestick or sharps injuries, write or review a bloodborne-pathogen exposure control plan, build a sharps injury log, evaluate safer devices, set a no-recapping rule, or plan post-exposure follow-up for a clinic, ward, lab, dental practice, or ambulance. It forces the engineering-control-first hierarchy (eliminate unnecessary sharps -> safety-engineered devices -> no-recapping / safe-disposal -> PPE last), records the de-identified OSHA Sharps Injury Log, and builds a confidential source-testing / PEP pathway (source patient and worker by role only). It refuses a behaviour-led "be careful" treatment where a sharp could be eliminated or engineered out. Grounded in OSHA 1910.1030 + the Needlestick Act and EU Directive 2010/32/EU. Decision-support only; a competent person must review.
license	Apache-2.0
metadata	{"author":"eyekyam","version":"1.0","category":"occ-health","tier":2,"audience":["M","C","F"],"industry":["All"],"jurisdiction":["All"],"status":"stable","plugin":"hse-healthcare","hse_reviewed_by":"","hse_reviewed_date":""}

Sharps & Needlestick Management

A consultant-grade, engineering-control-first sharps-injury prevention and bloodborne-pathogen exposure-control package for a named healthcare service or unit — a ward, clinic, community/home care service, dental practice, ambulance service, or clinical laboratory — never a generic "a clinic". Its entire reason to exist is that sharps safety leads with elimination and safety-engineered devices, not behaviour rules: every plan first records whether an unnecessary sharp can be eliminated or substituted (needle-free connectors, alternative routes); only the residual sharps are controlled by safety-engineered devices, then safe work practices (no-recapping, point-of-use disposal), with PPE and post-exposure prophylaxis as the documented last lines. A bare "staff to take care / wear gloves" is refused — a behaviour rule is an administrative control, never the primary control where the sharp could be eliminated or engineered out.

It forces the single lever that separates a defensible artifact from copy-paste paperwork: the elimination/safety-engineered-device decision plus the full hierarchy of controls, with the incident never identifying a person. Bloodborne-pathogen exposure data is special-category health data (PHI) — the source patient's identity and serostatus (HIV/HBV/HCV) and the injured worker's identity and PEP medical record are scrubbed to role labels before drafting (OSHA 1910.1030(f) confidentiality), the Sharps Injury Log in the circulated artifact is de-identified and aggregated (never line-level), and a sharps-injury category with fewer than 5 individuals is suppressed (small-cell back-calculation guarded). The skill never emits a re-identification / exposure key file — the key is an instruction to the competent person, held separately and access-controlled. Grounded in OSHA 29 CFR 1910.1030 ((c) Exposure Control Plan, (c)(1)(iv) annual safer-device evaluation, (d)(2) engineering & work-practice controls, (f) confidential post-exposure follow-up, (h)(5) Sharps Injury Log), the Needlestick Safety and Prevention Act (PL 106-430, 2000), EU Directive 2010/32/EU + the UK Sharps Regulations 2013 with COSHH, and India Bio-Medical Waste Management Rules 2016 sharps segregation via hse-india. Decision-support only; a competent person (occupational-health / infection-control professional) must review the output.

When to use this skill

Use this skill when the user needs a sharps-injury prevention / exposure-control plan for a concrete healthcare service — for example "prevent needlestick injuries on the phlebotomy round", "write a bloodborne-pathogen exposure control plan for the dental practice", "build a sharps injury log for the ward", "evaluate safer IV cannulae", or "plan the post-exposure follow-up pathway". It is not for a generic "how do I avoid needlesticks?" answer: the Workflow intake below forces the named service and its real sharps inventory, the elimination/substitution decision, and the safety-engineered-device process before any control plan, refuses a vague "a clinic" request, and refuses a behaviour-led "staff to take care / wear gloves" treatment where the sharp could be eliminated or a safety-engineered device fitted.

Data Protection & De-identification (MANDATORY — apply before drafting)

Apply this BEFORE you draft anything. Treat injury, illness, and any health detail as the highest sensitivity. Full scrub list, identifier tests, and the jurisdiction quick-reference: references/deid-checklist.md.

1. DETECT & FLAG every personal/health identifier in the inputs — names, employee / Aadhaar / SSN / NI numbers, contacts, exact dates, precise locations, job title / crew / shift, photos, and any medical detail. List what you found before drafting. If unsure whether something is identifying, treat it as identifying.
2. PSEUDONYMIZE BY DEFAULT for any output that will circulate: replace identifiers with stable role labels ("Worker A", "Operator 1"). Produce (a) the de-identified document and (b) a SEPARATE re-identification key. Never put the key or any name↔label mapping in the document. Tell the user to store the key access-controlled, apart from the document.
3. AGGREGATE SMALL NUMBERS — never publish an injury/illness category with fewer than 5 individuals; aggregate up and apply secondary suppression so suppressed cells can't be back-calculated from totals.
4. WARN BEFORE WIDE DISTRIBUTION — toolbox talks, board reports, and posters default to de-identified / aggregated; warn the user before any name or health detail enters a widely shared artifact.
5. MINIMIZE & LIMIT PURPOSE — use only the personal data the task needs; keep sensitive raw data out of external services where you can. When in doubt, ask before including it.

This skill is one of the catalog's highest-PHI artifacts. The reinforced healthcare PHI extension — the source-patient serostatus rule, the injured-worker OH-record rule, the <5 small-cell suppression with secondary back-calculation guard, and the re-identification-key-separation instruction — lives in references/deid-checklist.md and the Workflow de-id step below (it is NOT in the byte-identical block above).

Knowledge base (read ONE matching file — never load all)

Resolve the user's jurisdiction first. Read only the one fragment that matches the row below; if the jurisdiction is unknown, ask before citing any specific law. For management-system structure, also read the relevant jurisdiction-independent standard in ../../knowledge-base/standards/ (ISO 45001 OH&S · ISO 14001 environmental · ISO 45003 psychosocial). Always apply ../../knowledge-base/prompt-snippets/hierarchy-of-controls.md (KB-SNIP-HOC) to every control recommendation. For any benchmark/figure, look up the ID in the relevant _registry.yaml, then read ONLY the named file — and quote its source+year.

Jurisdiction / scope	Read
Sharps control spine (every run)	../../knowledge-base/prompt-snippets/sharps-hierarchy.md (KB-SNIP-SHARPS-HIERARCHY) — the eliminate → safety-engineered device → safe-procedure → PPE/PEP-residual sharps control gate: a PPE-led / "be careful" treatment of a sharp that could be eliminated or engineered out is rejected; exposure reporting is small-cell-suppressed
Healthcare clause cross-walk (every run)	../../knowledge-base/prompt-snippets/healthcare-clause-map.md (KB-SNIP-HEALTHCARE-CLAUSE-MAP) — the bundle-shared ISO 45001 6.1.2 + clinical PPE-last cross-walk that keeps the five hse-healthcare skills consistent
USA	../../knowledge-base/regulatory/osha-bbp.md (KB-REG-OSHA-BBP) — OSHA 29 CFR 1910.1030 ((c) ECP / (c)(1)(iv) annual safer-device evaluation with frontline input / (d)(2) engineering & work-practice controls / (f) confidential post-exposure follow-up / (h)(5) Sharps Injury Log) + the Needlestick Safety and Prevention Act (cite the paragraph topics, never paste the rule)
EU / UK	../../knowledge-base/regulatory/eu-sharps-2010-32.md (KB-REG-EU-SHARPS-2010-32) — EU Directive 2010/32/EU (eliminate unnecessary sharps, safer engineered devices, recapping ban, safe disposal, training, reporting + PEP) + the UK Sharps Regulations 2013 with COSHH (cite the member-state transposition for the binding duty)
India	../../knowledge-base/regulatory/in-bmw2016.md (KB-REG-IN-BMW2016) — India Bio-Medical Waste Management Rules 2016 sharps segregation (yellow/blue/white-translucent stream); defers to hse-india, mandatory state detection; emit [GAP], never a national form number
Unknown	Ask before citing any specific law

This skill always grounds in KB-STD-ISO45001 (6.1.2) and leads every plan with the sharps engineering-first spine KB-SNIP-SHARPS-HIERARCHY (eliminate the sharp → safety-engineered device → safe work practices → PPE/PEP residual), aligns with the other hse-healthcare skills through KB-SNIP-HEALTHCARE-CLAUSE-MAP, applies KB-SNIP-HOC to every control, and reuses the KB-SNIP-ARCHETYPES subagent roster. The control selection is a structured engineering-control-first method over the named device inventory + the cited OSHA/EU hierarchy — not a calculation (no new engine). For a US site ground in KB-REG-OSHA-BBP; EU/UK in KB-REG-EU-SHARPS-2010-32 (cite the member-state transposition); for India, resolve the state via hse-india (mandatory state detection) per the BMW Rules 2016, and emit a literal [GAP] where a state return is owed — never a minted national form number. The rule-9 manifest is references/_skill-kb.md.

Workflow

Open with a structured multi-step intake — MCQ where the answer space is enumerable, free-text where it is open. Ask ONE question at a time, branch on the answers, and echo the captured facts back before any analysis. Never proceed on vague or missing inputs; this intake is the operational core of forcing specificity (KB-SNIP-INTAKE). (Intake is a Workflow convention, not a sixth block.)

De-identify FIRST (the highest-PHI step — before any drafting). Run the deid block + references/deid-checklist.md BEFORE the intake echo-back drives any analysis. Bloodborne-pathogen exposure data is special-category health data: scrub the source-patient identity and serostatus (HIV/HBV/HCV — never written into a circulated plan; the source-testing pathway references "the source patient" by role only, with consent + a separate confidential record), the injured worker's identity, job, shift, and exposure/PEP medical record (role-label "Worker A"; the medical record is held confidentially, separate from the plan, per OSHA 1910.1030(f)), and any patient identifier anywhere in the inputs. Apply <5 small-cell suppression (with secondary suppression) to every sharps-injury category, and produce a SEPARATE access-controlled re-identification/exposure key — never co-located with the plan and never emitted as a key file.

Run the sharps intake one question at a time (full coverage contract + branch map in references/intake.md). Refuse to plan for "a clinic": you need the named service + its real sharps inventory + the elimination/substitution decision before any control plan. Refuse a behaviour-led "staff to take care / wear gloves" treatment where the sharp could be eliminated or a safety-engineered device fitted.

1. The named service & sharps inventory (free-text — the specificity anchor) — "Name the exact unit / service (ward, phlebotomy round, dental surgery, ambulance, lab) and the sharps actually used (hollow-bore needles, lancets, scalpels, IV cannulae, suture needles). Refuse 'a clinic' / 'the ward' — the plan is service-specific."
2. Can any sharp be eliminated or substituted? (mcq — asked FIRST among the controls) — yes → remove unnecessary sharps / substitute needle-free connectors: the plan leads with elimination · no → branch to engineering controls (Q3). Eliminating the sharp is the primary control, not the safety device.
3. Safety-engineered devices in use (free-text) — which devices have an integrated sharps-protection mechanism, which do not, and the frontline-worker selection process. A non-engineered device still in use without a recorded justification is FLAGGED — OSHA mandates a documented annual safer-device evaluation with non-managerial frontline-worker input.
4. Work practices & disposal (multi-select) — no-recapping rule · point-of-use sharps containers (fill line, location) · safe-disposal route · single-handed/scoop technique. A plan permitting recapping by hand fails.
5. Exposure response (free-text) — the post-exposure pathway: immediate first aid → confidential incident report → source-patient testing with consent and confidentiality → PEP timing for HBV/HCV/HIV → follow-up → the Sharps Injury Log entry. Refuse to draft a pathway that names a source patient or worker in the circulated plan.
6. Jurisdiction (mcq) — USA (OSHA 1910.1030) / EU (Directive 2010/32/EU + transposition) / UK (Sharps Regs 2013 / COSHH) / India / Other / Unknown. India → resolve the state via hse-india (mandatory state detection); BMW Rules 2016 sharps segregation; emit [GAP], never a national form number.

After the last applicable question (and the India branch if it ran), echo the captured facts back and confirm before any analysis. Never proceed on a vague or missing input — a missing input is a [GAP], never an invented device or count.

Then: record the elimination/substitution decision first (KB-SNIP-SHARPS-HIERARCHY); rank the residual controls up the hierarchy via the controls engine (eliminate → safety-engineered devices & containers → no-recapping/safe-disposal work practices → PPE last — a behaviour-led / PPE-led treatment where the sharp could be eliminated is a FLAG pushed up the hierarchy); record the documented safer-device consideration with frontline-worker involvement; build the confidential post-exposure (PEP) pathway (first-aid → report → consented source-testing → PEP → follow-up) and the de-identified/aggregated Sharps Injury Log structure; frame the residual sharps-exposure risk via risk_matrix; make every action a SMART action via smart_actions → validate the draft against references/QUALITY_CHECKLIST.md → produce the output via the Output format section below. The domain method is in references/METHODOLOGY.md.

Agentic Execution (Orchestration Block)

You are the ORCHESTRATOR for this skill. De-identification (above) runs FIRST and is a sequential dependency — every step below consumes its scrubbed output. Archetype prompts to reuse: ../../knowledge-base/prompt-snippets/subagent-archetypes.md (KB-SNIP-ARCHETYPES).

Step 0 — Triage: fan out at all?

Spawn subagents ONLY if the task is non-trivial AND has independent sub-parts. Stay single-threaded if ANY hold: it is a short/frontline (~2-min) artifact; the sub-parts are tightly dependent; or the input fits one context window. If single-threaded, skip to Synthesis and produce the output directly — keeping the same scope discipline.

Step 1 — Plan

Decompose into INDEPENDENT jobs. Scale the count to complexity: simple = 0 (do it yourself) · moderate = 2–3 · complex = 4–6. Never exceed MAX=6.

Step 2 — Fan out (parallel subagents)

Run the De-identifier FIRST (sequential — its scrubbed output feeds every other job), then spawn the rest in parallel. Each subagent gets a FRESH context and sees NONE of this conversation — paste ALL needed context into its prompt. Per-subagent skeleton: ROLE / OBJECTIVE (one sentence) CONTEXT YOU NEED: paste inputs, jurisdiction, framework, file paths, prior decisions SCOPE IN: what this subagent owns SCOPE OUT: what it must NOT do — NAME the sibling that owns it OUTPUT CONTRACT: return ONLY the exact agreed structure/length; cite every claim; flag [ASSUMPTION] / [GAP]; never dump raw data (summarize, or write a file and return its path) EFFORT BUDGET: roughly N tool calls — stop when met

Step 3 — Synthesis (you)

Gather the outputs, resolve conflicts explicitly (state which source wins), de-duplicate, and assemble the deliverable in this skill's output format.

Step 4 — SME Review & Sign-off (MANDATORY — regulatory/safety output)

Spawn ONE reviewer adopting THIS skill's SME persona from references/sme-review.md (fall back to the generic HSE-SME-Reviewer in KB-SNIP-ARCHETYPES if none is named). Give it the draft + the inputs + the output contract. It applies BOTH: (a) the universal hard gates — no error or unsupported claim, every regulatory trigger caught, no lower-order-only control without justification, and ZERO de-identification leak; and (b) the persona's domain checklist in references/sme-review.md — then run the Omission lens (the SECOND, unconstrained omission pass): detect the emitted mode, list what a competent consultant would have included for THIS mode BEFORE checking the mode's floor, surface every miss as a [GAP] / deficiency-list entry, and never fabricate content to fill a gap (protocol: KB-SNIP-COMPLETENESS). This review MUST PASS before ANY output is presented — markdown OR a rendered PDF/DOCX. Fix everything it raises and re-run until clean. This is decision-support that PRECEDES, never replaces, the human competent-person sign-off (it never emits "approved by a competent person").

Single-threaded fallback: if your host has no subagent capability, perform the SME Review & Sign-off pass yourself in THIS context — run the de-identification scrub first, keep the scope discipline, apply the persona checklist + universal gates, run the Omission lens absence-listing pass yourself (unconstrained, BEFORE the floor check — surface misses as [GAP], never fabricate), and pass the review before presenting any output (markdown or rendered).

Subagent roster for THIS skill

For a multi-area sharps program the triage gate fans out (moderate 2–3; the De-identifier runs FIRST — sequential dependency; everything below consumes only its scrubbed output):

• De-identifier — runs FIRST. Scrub every personal/health identifier — esp. the source patient's identity and serostatus (HIV/HBV/HCV) and a named injured worker's PEP medical record — to role labels before any analysis; apply <5 small-cell suppression (with secondary suppression) to every sharps-injury category; return the re-identification / exposure key SEPARATELY to the orchestrator, never to a sibling, and never as a key file.
• Controls-&-Device-Analyst — runs the elimination → safety-engineered-device → work-practice hierarchy via the controls engine: lead with eliminating unnecessary sharps; specify the safety-engineered devices + the documented safer-device consideration with frontline-worker involvement; define no-recapping + point-of-use disposal. A treatment that leads with "be careful / wear gloves" where the sharp could be eliminated or engineered out is a FLAG pushed up the hierarchy, never the headline control. SCOPE-OUT: does not author the PEP pathway / log (the Exposure-Response-&-Log-Author) or de-identify (the De-identifier).
• Exposure-Response-&-Log-Author — author the confidential post-exposure (PEP) pathway (first-aid → confidential report → consented source-patient testing → PEP timing for HBV/HCV/HIV → follow-up), the de-identified/aggregated Sharps Injury Log structure (never line-level identified), and the HBV-vaccination status. No source patient or worker is named in the circulated artifact. SCOPE-OUT: does not select the controls (the Controls-&-Device-Analyst) or de-identify (the De-identifier).
• Critic/QA (MANDATORY) — adversarial final pass: the elimination/substitution decision is recorded BEFORE any device or PPE, every non-engineered device carries a justification, the no-recapping rule is present, the annual safer-device consideration + frontline involvement is recorded, the Sharps Injury Log is de-identified/aggregated, the PEP pathway preserves source-patient and worker confidentiality, no <5 injury cell is published, and ZERO de-identification leak.
• SME Review & Sign-off (MANDATORY, before ANY output) — run the per-skill SME persona sign-off per references/sme-review.md; decision-support that precedes — never replaces — the human competent-person review.

Single-threaded fallback: run the De-identifier scrub first, then the elimination/substitution decision, the A7 controls / risk_matrix / smart_actions calls inline, the confidential PEP pathway + the de-identified Sharps Injury Log, then the mandatory Critic/QA + SME pass — same scope discipline, no subagents.

## Output format

Assemble a report.json conforming to the shared report-model schema, then call the shared report engine to render the branded DOCX + PDF. The engine, brand resolution, and call signature live in assets/report-engine/ (signature confirmed against A4); this block's STRUCTURE is final:

1. Build report.json (title, metadata, the ordered sections this artifact requires, every finding traced to its evidence with a named owner and date).
2. Resolve branding: the user's brand.yaml overrides the Eyekyam default.
3. Render both DOCX and PDF from the one report.json via the shared engine.
4. Surface the output paths and a one-line provenance note to the user.

Attribution (non-intrusive)

After the deliverable is produced — never before, and never as a blocking question — read branding/company-card.yaml and surface the company card per its placement:

• footer (default): one quiet line at the end, e.g. "Built by Eyekyam · HSE Leadership, operationalised · eyekyam.com".
• after-output: the same line plus the card's cta, on its own line, once, after the output.
• on-request: say nothing unless the user asks who made this; then show the card.

If show: false, omit attribution entirely — no line, no footer. Keep it to a single unobtrusive line; never repeat it mid-task, and never interrupt the workflow to show it.

Reference material

On-demand pointers (read only when needed):

• references/METHODOLOGY.md — the domain method this skill applies.
• references/intake.md — the structured-intake coverage contract + Q-table.
• references/sme-review.md — the per-skill SME sign-off personas + checklist.
• references/deid-checklist.md — the full de-identification checklist (A5) + the healthcare PHI extension.
• references/QUALITY_CHECKLIST.md — the pre-output validation gate.
• references/_skill-kb.md — the knowledge-base fragments this skill resolves.