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The Infectious Disease Society of America (IDSA) has provided comment on the Occupational Safety and Health Administrations (OSHA) Request for Information (RFI) on occupational exposure to infectious agents in healthcare-related settings. In an Aug. 4 letter to David Michaels, PhD, MPH, assistant secretary of labor, Richard Whitley, MD, FIDSA, president of the IDSA, explained that it has concerns about the potential scope and breadth of this potential undertaking because The advantages of establishing a new standard for healthcare workers can be easily outweighed by the unforeseen consequences caused by such a standard, particularly if the standard is not supported by scientific evidence. Whitley asks OSHA to directly involve expert stakeholder groups, such as IDSA, while investigating the need to create such a standard.
Whitley writes, With this RFI, OSHA appears to be moving in a direction similar to its bloodborne pathogen standard in terms of focusing on regulating exposure to infectious agents, rather than the prevention of the infections themselves. OSHAs bloodborne pathogen standard was valuable, in that it encouraged facilities to be proactive in the preparation for and the prevention of exposures to blood and body fluids. Taking a parallel approach for other occupational exposures may prove problematic. For example, a facility cannot prevent exposures to methicillin-resistant Staphylococcus aureus (MRSA) without universal screening for MRSA colonization or infection. A facility also cannot regulate a healthcare workers exposure to a patient with a respiratory infection without first instituting Centers for Disease Control and Prevention (CDC) guidelines. Of importance, compliance with existing CDC guidelines already is monitored by the Joint Commission, the Centers for Medicare and Medicaid Services, and at the local level by state health departments (with some having stricter standards than those at the federal level).
Whitleys letter continues, From a patient and healthcare worker safety perspective, IDSA strongly believes that setting a standard to regulate exposure, without addressing infection prevention and control, may create a host of unintended consequences. IDSA sees a need for greater infection prevention and control practices in hospitals as well as in non-traditional healthcare settings, such as in-home healthcare or same day surgery centers. Infection prevention and control through standard precautions and vaccination is evidence-based, whereas a standard focused solely on exposure, is not. Exposures occur in a variety of settings, and it is often difficult to determine where the exposure first occurred. Data presented by the CDC has shown that in the case of H1N1, many healthcare workers were exposed to the virus at home or in the community. As such, a standard focused on limiting exposures in healthcare and healthcare-related settings would have had less impact than a standard supporting mandatory vaccination of HCWs against H1N1 or seasonal influenza.
A final point made by Whitley is that a potential rule that covers all infectious diseases has the potential to be extremely impactful on facilities and facility resources, without necessarily achieving greater patient or healthcare worker protections. Whitley continues, A regulatory standard focused on exposures places an inherent burden on facilities to track and document the large number of potential exposuresthe vast majority of which are trivial in natureand are unlikely to lead to transmission (an example being a patient with a cold). The burden on smaller healthcare facilities could be enormous. Considering most U.S. hospitals have fewer than 100 beds, the burden on the facility to provide this level of documentation would be grave, not only impacting facility resources, but human resources as well. IDSA recommends OSHA take a measured approach by first evaluating the data on healthcare worker exposure to determine where deficiencies exist, rather than applying a regulatory standard to any and all modes of exposure in any and all potential healthcare or healthcare-related settings. Research funding to measure the best approaches is greatly needed. We caution OSHA to first focus on basic personnel and infection prevention and control policies before attempting to regulate infectious diseases exposure in the universe of healthcare settings. Finally, it is imperative that OSHA directly reach out to professional societies and other stakeholders during each step of this potential rulemaking, as it has the potential to radically impact healthcare in the United States. Such inclusion and a fully transparent process will help to ensure there are as few unintended consequences as possible, not only ones borne by facilities, but by patients and HCWs as well. IDSA stands ready to help.