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An OSHA Q&A on MRSA infections in the workplace

Working in a healthcare facility of any size means exposure to highly contagious MDROs such as MRSA is an everyday occurrence.  By wearing the correct personal protective equipment (PPE) and following standard precautions, workers can protect themselves from these infections, but what if an employee claims their MRSA infection was contracted at work?

The following questions were submitted through email to an OSHA spokesperson for clarification on how to determine if a MRSA infection is workplace related.

Q: What is the procedure per OSHA standards when a worker is exposed to MRSA from a patient?

A: As with any workplace hazard, employers are required to perform a hazard assessment and implement feasible measures for protecting employees (e.g engineering and administrative controls, as well as personal protective equipment, such as gloves, gowns and face masks.) An employer must make the determination as to what measures best protect the worker based on the tasks being performed. Please refer to the MRSA section of OSHA’s Hospital eTool [1] for a comprehensive set of information and guidance on workplace exposures to MRSA.

Q: What standard does a workplace MRSA infection fall under?

A: Compliance with several OSHA Standards will assist with improving the protection of employees who may be exposed to MRSA in the workplace. Please see [the OSHA site] for a Q&A which provides a list of OSHA standards of special importance [2].

Q: Is there a procedure to determine if a MRSA infection was in fact an occupational exposure?

A: Employers would need to use similar methods of evaluating exposures to other infectious diseases to which employees may be exposed. The CDC offers guidance on transmission prevention and exposure evaluation and management in their 2007 Guideline for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings [3]. With regard to OSHA investigations, this determination would be made on a case-by-case basis.

Q: If an employer enforces standard precautions, and provides proper training and PPE, but the employee fails to comply with protocols and ends up with a MRSA infection, is there any culpability on the employer’s part? Can they be cited even though they have taken the proper steps to protect employees?

A: That’s part of the case-by-case evaluation mentioned previously. OSHA investigators look at factors such as whether the employer was aware that the employee was not compliant with the precautions set by the facility, but still allowed employees to break the rules, or whether the employer had disciplined employees in the past for not complying. The final determination is based on the particular circumstances in each situation.

Q: Is there an obligation to pay for testing for employees potentially infected with MRSA?

A: As you know, there is no specific OSHA standard addressing this issue. However, healthcare settings would be considered responsible for the payment of tests determined to be necessary in the evaluation of an employee who has had an unprotected exposure.

Q: Should infections be recorded in the OSHA 300 log, injury an illness log?

A: Employers are required to record exposures on the 300 log if the exposure meets one or more of the criteria outlined in 29 CFR 1904.7 [4] through 1904.11 [5] (OSHA’s recordkeeping standard). For example, recordkeeping is required under the following circumstances: a MRSA exposure which leads to a) employees becoming infected as a result of a workplace exposure; b) medical treatment is provided to the exposed employee; or c) employees miss at least one full day of work.