OSHA Has Questions About Infectious Diseases. Is a New Standard Far Off?

OSHA announced yesterday that it is considering a new standard aimed at controlling worker exposure to infectious diseases. The agency invited interested parties to attend stakeholders meetings on July 29 in Washington D.C.

The meetings are a follow up to a Request for Information (RFI) OSHA published last year on the subject that elicited over 200 comments from various constituents. The RFI asked about the “nature and extent of occupationally-acquired infectious diseases and the strategies that are currently being used to mitigate the risk of occupational exposure to infectious agents.”

According to the official stakeholder meeting notice, the stakeholder meetings are intended to help OSHA determine what actions it should take to limit the spread of infectious diseases. Specifically, OSHA is looking to protect healthcare workers who have contact with patients – providing direct care or support services as well as those workers that handle infectious items (laundry, medical wastes, etc.) and perform autopsies or mortuary services.

A new standard centered on infectious diseases would likely require employers to incorporate the following elements:

  • A hazard assessment
  • A written exposure control plan or written worker infection control plan (WICP)
  • Methods of compliance
  • Engineering controls
  • Work practice controls
  • Administrative controls
  • Personal protective equipment
  • Medical surveillance
  • Worker training
  • Signage and labeling
  • Recordkeeping

OSHA uses stakeholder’s meetings to ask specific questions around regulatory issues. For the infectious disease meeting, OSHA has the following questions, among others:

  1. Whether and to what extent an OSHA standard on occupational exposure to infectious diseases should apply in settings where workers provide direct patient care, as well as, settings where workers have occupational exposure even though they don't provide direct patient care.  Whether and to what extent there are any other settings where an OSHA standard should apply.
  2. Whether and to what extent an OSHA standard should require each employer to develop a written worker infection control plan (WICP) that documents how the employer will implement the infection control measures it will use to protect the workers in its facility. Some of the elements that might be appropriate to include in such a worker infection control plan are: Designation of the plan administrator responsible for WICP implementation and oversight; designation of the individual(s) responsible for conducting infectious agent hazard analyses in the work setting; and written standard operating procedures (SOPs) to minimize or prevent exposure to infectious agents (e.g., SOPs for early identification of potentially infectious individuals and for implementation of standard and transmission-based precautions).
  3. Whether and to what extent SOP development should be based upon consideration of applicable regulations/guidance issued by the Centers for Disease Control and Prevention, the National Institutes of Health, and other authoritative agencies/organizations.
  4. Whether and to what extent an OSHA standard should require each employer to implement its WICP through a section addressing methods of compliance. OSHA envisions that this section would require, among other control measures, that an employer conduct an infectious agent hazard analysis, follow appropriate SOPs, institute appropriate engineering, work practice, and administrative controls, provide and ensure the use of appropriate personal protective equipment, clean and decontaminate the worksite, and conduct prompt exposure investigations.
  5. Whether and to what extent an OSHA standard should require each employer to make available routine medical screening and surveillance, vaccinations to prevent infection, and post-exposure evaluation and follow-up to all workers who have been exposed to a suspected or confirmed source of an infectious agent(s) without the benefit of appropriate infection control measures.
  6. Whether and to what extent an OSHA standard should contain signage, labeling, and worker training requirements to ensure the effectiveness of infection control measures.
  7. Whether and to what extent an OSHA standard should require the employer to establish and maintain medical records, exposure incident records, and records of reviews of its worker infection control program, and whether and to what extent an OSHA standard should contain other recordkeeping requirements.

If you are interested in attending the meeting, they will be held in Washington D.C. on July 29, 2011. The first one is from 9 a.m. to noon. The second one is 1:30 p.m. to 4:30 p.m. Registration is open through July 22.