Infection Control Today

JUN 2019

ICT delivers to infection preventionists & their colleagues in the operating room, sterile processing/central sterile, environmental services & materials management, timely & relevant news, trends & information impacting the profession & the industry

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23 June 2019 ICT the agency consider including process measures in addition to outcome measures as examples, particularly as it relates to the risk assessment process: "Given the known problems with under-reporting, it would be worthwhile to include an example measure related to needlestick injuries. Additionally, The Joint Commission recommends that the importance of examining trends over time be added to the discussion on performance measurement and quality improvement. Organizations should be encouraged to submit standardized data to reporting systems to receive comparative reports and track trends over time." The guideline currently says to "Inform all healthcare personnel and relevant healthcare organization departments about occupational infection prevention and control policies and procedures." The Joint Commission asserts that in this context, "use of the word 'informing' in this requirement implies that no ac tion is required by healthcare personnel in an element that is crucial to effective implementation of safe occupational health practices. The Joint Commission proposes that this sentence be revised to "ensure all healthcare personnel and relevant healthcare organization departments understand their role in imple- menting occupational infection prevention and control policies and procedures." The Joint Commission also recommends that the CDC add language to the guideline that would require drills based on insti- tutions' infectious disease emergency and outbreak management plans, and observes, "IPC-related emergencies are more likely to happen than many other emergencies that organizations are required to drill. In guidance for surveyors, providers and suppliers for natural disaster preparedness, CMS notes that 'in keeping with the all-hazards methodology, infectious diseases pose a threat to the community, healthcare workers as well as national response and recovery efforts.' When this type of emergency occurs, the results can negatively impac t the availabilit y of healthc are personnel and creates potential for exposures in the community. Encouraging organizations to drill response to IPC-related emergencies ensures readiness and could dramatically decrease exposures and illness." Finally, the Joint Commission calls for the CDC to consider adding a requirement to ensure the availability and use of task-specifc engineering control and PPE for high-risk situations based on HCO experience: "Since exposures of healthcare personnel happen every day in healthcare, leaders need to set clear expectations of where PPE should be stocked and when PPE must be worn. It has been shown that healthcare personnel wear gloves but often do not wear other essential PPE. For example, EPINet data on splash exposures indicates that, in 2017, approximately 62 percent of exposures involved a splash to the eyes, nose or mouth, but exposed healthcare personnel reported wearing face protection during less than 12 percent of exposures." AFL-CIO In public comments from the American Federation of L abor and Congress of Industrial Organizations (AFL-CIO), Rebecca L. Reindel, MS, MPH, senior safety and health specialist, referenced the long-es- tablished industrial hygiene practice called hierarchy of controls: "It is widely instituted and recognized because it is the most effective method of controlling hazardous exposures, including biological exposures, and recognizes the environment of the worker, rather than only the worker and the worker's task, in the exposure control model. According to the hierarchy, the most effective method for controlling workplace hazards begins with substitution with a safer product or process; followed by engineering controls such as isolation or installation of safety engineered Sharps devices; administrative and work practice controls; and only as the fnal line of defense, per sonal protec tive equipment (PPE), including respiratory protection, gloves and protective clothing. It is fully recognized, and often in healthcare, that PPE can be used in combination with other control measures but should not be the primary reliance of protection to protect workers and bystanders, such as other workers and the public at-large." The AFL-CIO explains that the hierarchy of controls has been adopted by industrial hygiene professionals, health and safety professionals, public health organizations, b u s i n e s s e s a n d r e g u l a to r y a g e n c i e s throughout the U.S. and the world. Most notably, OSHA has incorporated the hierarchy of controls into every health standard it has issued, requiring that engineering and administrative controls be implemented frst and fully to reduce exposures. The AFL-CIO clarifes that the hierarchy of controls does not prohibit all respirator use: "OSHA's Respiratory Protection Standard, 29 CF R 1910.3 4 s t ate s: 'Re sp irato r y protection is a backup method which is used to protect employees from toxic materials in the workplace in those situations where feasible engineering controls and work practices are not available, have not yet been implemented, are not in themselves suffcient to protect employee health, or in emergencies.' However, respirators have significant limitations and deficiencies, and are less effective than engineering and work practice controls. In addition to exposing coworkers and others nearby to an infectious agent while wearing a respirator, it is dif ficult for worker s to breathe, especially when performing heavy physical labor; respirators are uncomfortable to wear, especially in hot environments; and it is diffcult for workers to communicate with each other, which compromises safety. Using respirators are diffcult to implement — they are required for ever y person, and the process for selecting, supplying and maintaining their effec tiveness if done properly can be resource intensive. People do not always wear them correctly, sometimes do not have them available and respirators alone are not suffciently protective for certain tasks." The AFL-CIO asked the CDC to more strongly emphasize the hierarchy of controls in the proposed updated guideline and noted, "By updating and improving these guidelines, CDC has a signifcant opportunity to address the incidence and spread of occupational illness … we urge CDC to revise its guidelines to refect current standards and practice to eliminate or reduce worker risks to biological exposures." The IP's Role T h e I nte r nat i o nal S afet y Ce nte r's Amber Hogan Mitchell suggest s that infection preventionists have a role to play. "Infection prevention starts frst with clinician self-care," Mitchell says. "The best way to protect patients from healthcare associated infections, is to frst start with personal (clinician) infection prevention meaning careful attention to adherence to the hierarchy of controls, including the use of engineering controls, safe work practices, and better compliance with PPE use. If clinician infection prevention is in place and solid, it provides the foundation for a facility's capability to best protect its patients from harm." Ò Encouraging organizations to drill response to IPC-related emergencies ensures readiness and could dramatically decrease exposures and illness.

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