OSHA explains what’s behind the push for an infectious diseases standard
The July issue of Medical Environment Update looks at how a new infectious diseases standard would affect compliance within medical facilities. The newsletter also posed questions to OSHA as to why the agency decided to broaden the request for information, how an OSHA standard would differ from existing CDC guidelines, what hazards will be covered, and when a standard would be in place?
Here, as a web exclusive, is how an OSHA spokesperson responded to questions submitted by email.
Medical Environment Update (MEU): Why is OSHA leaning towards an infectious disease standard as opposed to an aerosol transmissible disease standard?
OSHA: OSHA recently issued a Request for Information (RFI) on Infectious Diseases to gather information on occupational exposure to infectious agents. OSHA revised the scope to now encompass all infectious diseases not already covered by the OSHA bloodborne pathogens standard. This small but significant change will allow the agency to consider not just droplet and airborne disease transmission, but now contact transmission as well. The agency made this change in recognition that many diseases are spread through multiple routes and controlling occupational exposure may necessitate a more comprehensive approach. Additionally, since the CDC and healthcare industry’s voluntary guidelines for transmission-based precautions are comprehensive in nature, OSHA wants to consider an approach that is compatible. OSHA will use the information received in response to this request to determine what action, if any, the agency may take to further limit the spread of occupationally acquired infectious diseases in these types of settings.
MEU: What is the authority for OSHA standards as opposed to CDC guidelines?
OSHA: The Centers for Disease Control and Prevention (CDC) issues guidelines on infection control in U.S. healthcare facilities. While these recommendations have been endorsed by numerous professional associations and are widely recognized, they are non-mandatory in nature and day-to-day compliance, surveillance and oversight is left to each individual employer. There are numerous studies that show poor adherence to recommended voluntary infection control practices. Under the Occupational Safety and Health Act, employers have a responsibility to provide a workplace free from recognized hazards. An OSHA standard is just one possible approach to assuring that workers are adequately protected. For example, OSHA’s bloodborne pathogens standard has been very effective at controlling transmission of bloodborne diseases. However, until the agency has completed the RFI process, it is unclear what future actions may be necessary or appropriate to protect workers.
MEU: What specific hazards will be addressed?
OSHA: While OSHA is concerned about the risk to the nation’s 16.5 million healthcare from infectious diseases, the agency has not yet drawn any conclusions about the nature or magnitude of the problem. By its very design, a RFI is broad in nature to allow the agency to gather the full range of information on infectious diseases to help the agency better assess the extent of the problem and better understand ways to protect healthcare workers from infectious diseases.
MEU: What is the process for this kind of regulation, and what else has to happen?
OSHA: The information received in response to the RFI will be carefully reviewed and will assist OSHA in determining what action, if any, the agency should take in this area. If the agency decides to pursue rulemaking on this issue, the rulemaking process is quite lengthy and takes years to complete because of both the substantial evidentiary requirements and the opportunities for public notice and comment at each step in the process.
Do you intend to comment on the Infectious Diseases RFI? Submit comments electronically for docket number OSHA-2010-0003 at www.regulations.gov. The comment period closes August 4.
Also, check the OSHA Healthcare Advisor poll on this topic to see where you stand compared to your colleagues.
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