long-term care infection prevention
By Cindy Fronning , RN , GERO-BC , IP-BC , AS-BC , RAC-CT , CDONA , FACDONA
The Long-Term Care Perspective
Although the BBP standard is the main OSHA regulation that long- term care facilities must follow , the premise of OSHA is one that we as employers must keep in mind at all times ; to provide a safe and healthful working environment for our workers , and it carries a very high priority .
Recently I had a facility inquire what the Occupational Health and Safety Administration ( OSHA ) had to do with nursing homes . She had been asked for a bloodborne pathogen ( BBP ) plan and didn ’ t have one . She was of the opinion that she didn ’ t need one since her facility was a nursing home and not a hospital or industry-driven organization .
First , some history . OSHA was established under the Occupational Safety and Health Act of 1970 . It was created to ensure safe and healthful working conditions for workers by setting and enforcing standards and by providing training , outreach , education and assistance .
The Occupational Exposure to Blood Borne Pathogens Standard , § 1910.1030 ( d ) ( 3 ) ( 56 FR 64175 ) published in 1991 , protects workers who can reasonably be anticipated to contact blood or other
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potentially infectious material ( OPIM ) as a result of performing their job duties . This applies to any employer with this potential — hospitals , post-acute facilities , freestanding labs , etc .
The Centers for Disease Control and Prevention ( CDC ) estimates that 5.6 million workers in the healthcare industry and related occupations are at risk of occupational exposure to bloodborne pathogens , including human immunodeficiency virus ( HIV ), hepatitis B virus ( HBV ), hepatitis C virus ( HCV ), and others . All occupational exposure to blood or other potentially infectious materials ( OPIM ) places workers at risk for infection from bloodborne pathogens .
Other potentially infectious materials include other body fluids such as semen , vaginal secretions , cerebrospinal fluid and saliva to name a few .
In the years following the BBP standard ’ s publication , the CDC found that nearly 600,000 percutaneous injuries were sustained by healthcare workers annually involving contaminated sharps . Due to the concern over these exposures and the technological developments which can improve employee protection , the Needlestick Safety and Prevention Act was passed in 2000 which directed OSHA to revise the BBP Standard , requiring employers to identify and make use of effective and safer medical devices . This revision was effective April of 2001 .
So , what does this mean for long-term care facilities ? The BBP standard must be followed . The BBP plan must have these components :
A written exposure plan to eliminate or minimize exposures that identifies which job classifications are at risk , together with a list of task / procedures that might result in an exposure .
The plan must be updated annually to reflect the following :
●Changes in tasks / procedures ●Positions ●Technological changes that might eliminate or reduce exposure ●Use of safer medical devices ●Document solicited input from frontline workers in identifying , evaluating and selecting effective engineering and work practice controls . ●Implementation of standard precautions .
Identify and use engineering controls such as sharps disposal containers , self-sheathing needles and sharps with engineered sharps injury protection and needleless systems .
Identify and ensure the use of work practice controls . These are practices that reduce the possibility of exposure by changing the way a task is performed .
Provide personal protective equipment ( PPE ), such as gloves , gowns , eye protection , and masks and the necessary fit testing if using N95 respirators .
Make available hepatitis B vaccinations to all workers with occupational exposure .
Make available post-exposure evaluation and follow-up to any occupationally exposed worker who experiences an exposure incident . Use labels and signs to communicate hazards . Provide information and training to workers Maintain worker medical and training records including sharps injury log
Although the BBP standard is the main OSHA regulation that long-term care facilities must follow , the premise of OSHA is one that we as employers must keep in mind at all times ; to provide a safe and healthful working environment for our workers , and it carries a very high priority . Whether it is workplace violence , emergency preparedness or BBP we must be aware and always seeking ways to improve and provide the best working place we can for our employees .
COVID -19 placed a huge burden on the post-acute arena to not only keep our residents and clients safe and infection free but also our employees . Many of us lost employees to this pandemic ; those employees may have contracted the infection in the community or possibly at work . With that in mind we have reporting responsibilities not only to the Centers for Medicare & Medicaid Services ( CMS ), CDC , NHSN but also to OSHA .
OSHA was and is very much involved as evidenced by the three Interim Enforcement Response plan memorandums issued April 13 , 2020 , May 19 , 2020 , and March 3 , 2021 involving annual fit testing of respiratory protection ; six enforcement discretion memorandums dating from March 14 , 2020 to Oct . 2 , 2020 regarding respiratory protection ; and three other memorandums addressing recording and reporting occupational injuries and illnesses and various standards that require annual or recurring audits , reviews , training or assessments .