AHA: No on OSHA infectious diseases standard

By: August 6th, 2010 Email This Post Print This Post

Claiming that hospitals already have comprehensive programs in place to protect not only patients but also healthcare workers from the hazards of infectious diseases, the American Hospital Association (AHA) is advising OSHA not to promulgate a standard specific to diseases transmitted by contact, droplet, and aerosol modes.

The AHA letter was submitted on August 4, the closing day set by OSHA for public comment. It points out: “The existing infection prevention and control standards, including their assessment and enforcement by regulatory, accrediting and certifying bodies, have proven to be functional and appropriate, and substantial resources are dedicated to their regular maintenance and improvement.”

In other words, following CDC guidelines and enforcing those guidelines through accreditation organizations such as The Joint Commission and CMS is already protecting healthcare workers without the need for a federal standard.

There were approximately 227 other public comments submitted on the matter.


By Henry Botuck on August 6th, 2010 at 1:59 pm

AHA may think that it is the only game in town, but others, such as private medical offices and dental offices also need standards. This is especially necessary in dental offices because of the aerosols produced by the air driven handpiece and the ultrasonic scaler.

Henry, are medical and dental offices following the CDC guidelines?

OSHA is going to have a tough time with this one. This is similar to what occurred with the Tuberculosis standard that OSHA proposed back in 1997. The federal register records this as the reason for the withdrawal of the TB standard. “OSHA withdrew its 1997 proposed standard on Occupational Exposure to Tuberculosis because it is unlikely to result in a meaningful reduction of disease transmission caused by contact with the most significant remaining source of occupational risk: exposure to individuals with undiagnosed and unsuspected TB.”

OSHA further stated “Moreover, much of the current occupational transmission appears to occur when workers do not realize that a patient, client, or other contact has infectious TB. An OSHA standard is unlikely to be more effective than the Center for Disease Control and Prevention (CDC) guidelines in eliminating this risk. OSHA believes that workers in many situations, particularly those with limited medical qualifications and resources, will not be able to identify or diagnose currently undiagnosed TB cases frequently and rapidly enough to prevent this transmission from occurring”

So if they felt this way about TB, why would they have a different opinion for other infectious diseases? In my system, the exposures we do have occur prior to the disease being diagnosed.

We also had an issue on why health care is being targeted? A checker at Walmart has more potential for exposure than most health care workers – Ever seen a checker at your local supermarket wash or sanitize their hand between handling your produce, your credit card or your money?

By Henry Botuck on August 10th, 2010 at 11:47 am

Bruce has some good points. However, he doesn’t understand the special circumstances in a dental office. The high speed handpiece and the ultrasonic scaler put out not only droplets, but aerosols at about 100,000 particles per cubic meter. Most of these particles are five and ten microns in size. These aerosols increase bacteria (aerobic and anaerobic) and viruses by about 3,000% in a cloud over the dentist, the patient, and the assistant. In addition, there is blood in the aerosols. Not only do these aerosols strike the dentist and staff in the face and mask, but they float in the room for hours.
According to the FDA, surgical masks filter only about sixty percent of the aerosols. CDC recommends that when physicians create aerosols during bronchoscopy that they should wear N-95 respirators. But, there is no requirement that dentists do ANYTHING to protect themselves or their staff from the potential pathogens that they may encounter. Studies have shown that dentists have greater antibodies to some viruses than controls. It stands to reason that there is a high potential for the transmission of disease in the dental office. It is high time that there are some standards for air born, along with blood born pathogens.

By Pameal Dembski Hart on August 10th, 2010 at 3:14 pm

Hospitals may THINK they have a comprehensive program.. but evidence of disease transmission both infectious and communicable between patients and healthcare workers demonstrates otherwise. Whats even worse is the care provided in most ambulatory sites: (ASC’s, medical and dental offices and nursing homes is even worse. Safe practices are not enforced and education is seriousl lacking.Oversight is minimal at best. If the healthcare industry is so compliant as purported by APIC and AHA then how do you explain the more than 200,000 patients who have been exposed to HAI’s across the country due to unsafe injection practices and a general lapse in infection control????????????? Something must be done and what’s in “place” is NOT working.

Whoa, Pameal! I don’t know where you’re located, but our ASC is the cleanest and most up-to-date on education in town. Ask the 40 per diem nurses who work at the hospitals here about how much cleaner and better run our ASC is. Those of us who provide excellence in care and environment for our patients take offense to your broadbrush statement.

One of the problems as both Susan & Pamela point out in their respective comments is the disparity in infection prevention, control, & oversight in ASC settings. It is my opinion the intent of the OSHA standard is to provide consistent & nuanced structure in defining how we deal w/increasingly more antibiotic resistant microbes as well as communicable disease transmission. As a relatively new infection preventionist for my organization which has 4 ASCs, I have observed that not all staff are created equal in their understanding & responsibility to reduce transmissible conditions. IC process structure is key. Also, having CEO & Governing Body support is critical and ensures infection prevention efforts are successful.

As a worker in long term care and the infection preventionist for the facility I work in, I take offense at Pams remark that includes nursing homes. One must remember that nursing homes are just that, a residents home. Even though these residents are living in a group setting and have developed some contagious infections, we must remember to isolate them only to the degree that is absolutely necessary. I believe that her overall assumption that education is lacking and that we perform unsafe practices is unjustified. I agree with Lynne that not all staff are equal in terms to their understanding and implementing of infection control practices, but with continued inservices and surveillance of staff our goal is to make the understanding more equal throughout the facility. Following the CDC recommendations and having in place the policies and procedures to facilitate the precautions that are necessary goes a long way in keeping our facilities residents,employees and visitors at a lessor risk for development of various HAI’s.


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