In a July 5, 2011 Federal Register notice (76 FR 39041), OSHA announced two informal stakeholder meetings to solicit comments on exposure to infectious diseases in some workplaces. OSHA plans to use the information gathered at these meetings to explore the possible development of a proposed rule to protect workers from occupational exposure to infectious agents in settings, either where workers provide direct patient care or where workers perform tasks other than direct patient care that also have occupational exposure. These other tasks might include such tasks as:
- Providing patient support services (e.g., housekeeping, food delivery, facility maintenance);
- Handling, transporting, receiving or processing infectious items or wastes (e.g., laundering healthcare linens, transporting medical specimens, disposing of medical waste, reprocessing medical equipment);
- Maintaining, servicing or repairing medical equipment that is contaminated with infectious agents;
- Conducting autopsies (e.g., in medical examiners' offices);
- Performing mortuary services;
- Performing tasks in laboratories (e.g., clinical, biomedical research, production laboratories) that result in occupational exposure.
One action the Agency is considering is the development of a program standard to control workers' exposure to infectious agents in the above settings. OSHA notes, “A typical OSHA program standard affords employers substantial flexibility in determining the best way to tailor protective measures to their workplaces. Program standards generally involve: A hazard assessment; a written exposure control plan; methods of compliance (e.g., engineering controls, work practice controls, administrative controls, and personal protective equipment); medical surveillance; worker training; signage and labeling; and recordkeeping. A program standard to control occupational exposure to infectious diseases would likely incorporate all these elements.”
Stakeholder Meeting Logistics
Both meetings will be held at the Francis Perkins Building, Room N-4437 at 200 Constitution Avenue, NW., Washington, DC 20210. The first meeting will take place from 9 a.m.-noon and the second meeting will take place from 1:30 p.m.-4:30 p.m.
The deadline for confirmed registration at the meeting is July 22, 2011. However, if space remains after this deadline, OSHA may accept additional participants until the meetings are full. Those who submit their registration after July 22, 2011 may not receive confirmation of their attendance from OSHA.
The stakeholder meetings will be conducted as group discussions on views, concerns, and issues surrounding the hazards of occupational exposure to infectious agents and how best to control them. Formal presentations by participants will not be permitted.
Approximately 30 participants will be accommodated in each meeting, and three hours will be allotted for each meeting. Members of the general public may observe, but not participate in, the meetings as space permits. The morning and afternoon meetings will cover identical information and participants may attend only one session to allow
greater stakeholder participation.
Stakeholder Meeting Discussion Topics
Discussions will focus on issues such as:
- 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.
The advantages and disadvantages of using a program standard to limit occupational exposure to infectious diseases, and the advantages and disadvantages of taking other approaches to organizing a prospective standard.
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.
Whether and to what extent standard operating procedure (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.
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.
- 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. Whether and to what extent an OSHA standard should contain signage, labeling, and worker training requirements to ensure the effectiveness of infection control measures.
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.
- The economic impacts of a prospective standard.
Whether and to what extent OSHA should take alternative approaches to rulemaking to improve adherence to current infection control guidelines issued by the Centers for Disease Control and Prevention, the National Institutes of Health, and other authoritative agencies/organizations.
On May 6, 2010, OSHA published a Request for Information, entitled ``Infectious Diseases'' (Docket Number: OSHA-2010-0003). The Agency was interested in more accurately characterizing 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. More than 200 comments were received in response to the RFI. Based upon these responses and an ongoing review of current literature on this subject, OSHA is considering what action, if any, the Agency should take to limit the spread of occupationally-acquired infectious diseases.
A copy of the July 5, 2011 Federal Register notice is attached.