Thanks David! It does fall under the QSA regs for BB in the JC standards, so the policy is "owned" by me, and I "oversee" it. Though you are correct, the procedures are not being performed by lab staff, but by nursing staff only. This is done in many places in the hospital, including outpatient clinics, again by nursing staff only. I'm pretty sure this falls under nursing competency, but venipuncture is venipuncture is it not? I have never had anyone complain about nursing comps for t-phleb specifically, its so crazy to me!