Relating to the use of an epinephrine delivery system by certain entities.

Contracts

• Physician Standing Orders: CRITICAL. You must secure a new standing order from your prescribing physician. If your current order specifies "auto-injector" and a staff member administers a "nasal spray," you are operating outside the order, potentially voiding civil immunity. The new order must authorize "epinephrine delivery systems."
• Training Vendors: Amend scopes of work for third-party CPR/First Aid trainers. Contracts must explicitly require instruction on the specific device type (spray vs. injector) you intend to stock.
• Waste Disposal: Review contracts with medical waste handlers. Nasal sprays are pressurized canisters, not sharps; verify if they can be commingled in existing sharps containers or require separate segregation.

Hiring/Training

• Retraining Required: Staff trained on the "Blue to the Sky, Orange to the Thigh" method for auto-injectors will fail to administer a nasal spray correctly. Immediate retraining is required upon procurement of new devices.
• Visual Aids: Replace laminated instructional placards in first-aid kits. Diagrams must match the stocked device.

Reporting & Record-Keeping

• Policy Manual Updates: Conduct a global "Find and Replace" in all internal compliance manuals. Change "Epinephrine Auto-Injector" to "Epinephrine Delivery System."
• Incident Reporting: Schools, Higher Ed, and Day-Cares must report administration to the Commissioner of State Health Services and the prescribing physician within 10 business days.
• Data Granularity: Reporting forms must be updated to capture the *method of delivery* (intramuscular vs. intranasal) to satisfy state data collection requirements.

Fees & Costs

• Procurement Savings: No new state fees. Potential operational savings exist if nasal spray units have a lower price point or longer shelf-life than auto-injectors.
• Inventory Management: You may utilize existing auto-injector stock until expiration.