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Calls for Worker Infection Control Plan’ to prevent occupational infections
Though the timing with the Ebola outbreak is purely coincidental, the Occupational Safety and Health Administration (OSHA) has drafted an infectious disease standard that would mandate infection control measures to protect health care workers.
The 38-page "regulatory framework" document outlines requirements for hazard identification, exposure control, and creation of a Worker Infection Control Plan (WICP) for those at risk of occupational infections. OSHA has been working on the rule for some time, but knows it will get considerable pushback from hospitals. Representatives of small hospitals have already come out against it, saying its burdensome requirements are redundant with existing measures. (See related story, p. 7.)
While the Association for Professionals in Infection Control and Epidemiology (APIC) has not formally commented on the OSHA draft, the writing on the wall is clear enough in APIC’s recent comments to the agency on its proposed extension of the information collection provisions of the Bloodborne Pathogens Standard.
"APIC is concerned that OSHA’s estimate of the burden associated with information collection is underestimated," the association stated in the Dec 2, 2014 comments. "The 2011 Exposure Prevention Information Network (EPINet) reports for sharps and body fluids reveal almost one thousand events in just 32 sites. When considering the multiple settings where the standard applies as well as the time required by occupational health and infection prevention staff to investigate events, obtain and relay laboratory results, and manage the employee health records, the adjustment in the time estimate would seem significant."
Infection preventionists made similar arguments in fighting an epic and ultimately successfully battle in the 1990s against OSHA’s proposed standard to protect health care workers from tuberculosis. The proposed infectious rule could suffer the same fate, but the recent highly publicized Ebola infections in two Dallas nurses — who ultimately recovered — could give OSHA some political momentum.
As a result of the infections and the ensuing confusion about personal protective equipment, the Centers for Disease Control and Prevention upgraded their original recommendations to include respirators and increase the margin of safety for workers. OSHA broke the relative silence it had maintained on Ebola by issuing a firm reminder that "Under the Bloodborne Pathogens standard, and the PPE and other standards, OSHA has the ability to require employers to fully protect healthcare and other workers who may be exposed to Ebola virus."
The agency further warned employers that the OSH Act protects workers who complain to their employer, OSHA or other government agencies about unsafe or unhealthful working conditions in the workplace. "You cannot be transferred, denied a raise, have your hours reduced, be fired, or punished in any other way because you used any right given to you under the OSH Act," OSHA stated.
The OSHA infectious disease draft is modeled in part on the California Aerosol Transmissible Disease standard — which covers infections that are spread by the droplet and airborne routes — and includes some existing requirements in the OSHA Bloodborne Pathogen Standard. While this has been generally reported as good news, there is one troubling caveat.
"California regulated quite significantly years ago and yet we haven’t seen a meaningful change in terms of infection control," says Michael Bell, MD, deputy director of the Centers for Disease Control and Prevention’s Division of Healthcare Quality Promotion. "It’s not as easy as saying there’s a standard and therefore everything’s better. I don’t think people are trying to get themselves in harm’s way and I don’t think individuals are trying to kill patients. But it’s happening and it’s going to take more than a standard to change it."
As you might expect, OSHA sees it quite differently, with a spokesperson telling our sister publication Hospital Employee Health that health care workers "face a number of infectious diseases, and there are always new threats over the horizon MERS, Avian Flu, and, of course, Ebola. The infectious disease standard would require employers to have a plan to protect their employees from any infectious disease, rather than going on a disease-by-disease basis."
That leads us back to the Worker Infection Control Plan (WICP), OSHA’s primary tool to prevent occupational infections in the draft rule. The OSHA infectious disease draft — which has not been submitted for comment — calls for measures in the proposed WICP that include the following:
Each employer having an employee(s) with occupational exposure during provision of direct patient care and/or performance of other covered tasks would be required to develop and implement a written WICP designed to prevent or minimize the transmission of infectious agents to each employee. The exposure determination would be required to be made without regard to the use of PPE and would be required to contain a list of all job classifications in which all or some of the employees in those job classifications have occupational exposure.
The WICP should include the name and title of, and contact information for, the plan administrator responsible for WICP implementation and oversight (e.g., infection preventionist, occupational health professional, biosafety officer). Each employer would be required to ensure that a copy of the WICP is provided and accessible to all of its workers. During development and reviews of the WICP, the employer would be required to solicit input from non-managerial workers with occupational exposure regarding the WICP’s implementation and possible improvements; and establish and maintain records. The WICP would be required to be reviewed and updated at least annually, and whenever necessary to reflect changes in occupational exposure resulting from:
New or modified job tasks and procedures
New or revised job classifications
Changes in technology, updated federal, state, local, and other infection control guidelines, updated vaccination recommendations, or other medical advances that prevent or minimize transmission of infectious agents
New or emerging infectious agents, or changes in community patterns of infectious diseases (e.g., emergence of an antibiotic resistant infectious agent, an outbreak or a change in prevalence of an infectious disease).
[Editor’s note: The draft version of OSHA’s Infectious Diseases Regulatory Framework is available by going toregulations.gov and entering document number OSHA-2010-0003-0245 in the search bar.]