PPE and Industrial Managers
Vol. 21 No. 1
Much has been written about PPE. Constant pounding on providers for the necessity and continued practice of 'universal precautions' will not prevent all types of exposures, nor were they ever designed to. In the real world of patient care, "@* happens", and the goal of any well designed infection control plan, and the goal of any Infection Control Manager (yes, you must have one), is to keep the exposures to an absolute minimum. Well designed and implemented infection control plans will help keep the providers on their toes and constantly practicing their craft with meticulous safety whenever possible. They will also help companies meet requirements necessary for governmental scrutiny.
Governmental oversight is no laughing matter and any well seasoned supervisor that has survived an audit from the "sphincter police" can attest to the need for meticulous record keeping. Believe it or not, the government will tell you exactly what you must have. This is NOT a secret, and they will even help you with managerial training, and even with on-site visits if necessary. Honest, they are willing to help you with this, but you must ASK!
The federal regulations are vast, detailed, often very complicated, and can span various industries that may not be applicable to your industry even within the same regulation. Case in point, the Bloodborne Pathogen standards are located under 29 CFR (Code of Federal Regulations), part # 1910, OSHA (Occupational Health and Safety Standards), subpart Z, subpart title, "Toxic and Hazardous Substances", Standard # 1910.1030, title "Bloodborne Pathogens", appendix A. And that is only where they start. They continue from there. Go take a look. They are easily accessed at the OSHA web site at www.OSHA.gov and you should be very familiar with them IF you are the infection control manager OR their immediate supervisor.
An infection control plan is not difficult to put together, but it does take some time and a certain amount effort to get it to the point where it will pass muster with the regulators when they come for that eventual visit. Don't wait until you have the nasty workplace accident that is going to be investigated by OSHA and end up with nothing but your "mouse in your hand" trying to put something together at the last minute. Trust me that will not fly with the OSHA investigators.
So, what is it going to take to get an effective plan for your company? Obviously there is not enough space here to outline a total infection control plan. The easiest thing to do to find an example is to do a web search. I 'Googled' a simple search under "infection control plans" and came up with multiple hits and even a full example from my sister institution up in Reno, UNR. The University of Nevada, Reno has their complete infection control plan up on the web at: http://www.ehs.unr.edu/Portals/12/Bloodbrnd.pdf This is a complete plan that follows the 29 CFR right to the letter and while it may be tailored to a higher-educational institution, it is a good place to start and is as complete as any infection control plans that I have seen or written myself. This was NOT the only one that I found, merely the first. There were many more, pages more, and while I did not search through all of the pages, some may be tailored specifically to your needs. That is what doing research is all about.
Ok, so now you have the Infection Control Plan written and in place, now what do you do? Well, you have to bring the employees up to speed and compliance with all the necessary training and have the necessary and mandatory documentation to support the plan. Without the supporting documentation, you have nothing but a pretty manuscript. The training is not just about the use of PPE, yes that is there, and requirements for the employee compliance with the rules must be laid out to the employee including the disciplinary actions for non-compliance. Safety actions, reporting requirements, documentation requirements, etc., all outlined in the 29 CFR, must be promulgated to the employee and documented in the training components of the requirements. These are often signed off by the employee as having received this training and kept on file with the Infection Control Manager. Other required documentation would be for injury such as needle sticks or equipment evaluations from employees. There are quite a few under the code. Some examples (albeit, probably not a complete listing) could be found at the University of Medicine and Dentistry of New Jersey (UMDNJ) infection control plan at: http://www2.umdnj.edu/eohssweb/publications/UMG2004ECP.pdf. Here were some samples for training records and forms for the reporting of injuries due to needle sticks or other forms of injury involving bloodborne pathogens.
Complete credit is always given to the fine infection control managers who have, in the interest of sound infection control practices, posted these infection control plans for the perusal, examination, and use of others. It is truly the overall benefit that is sought here, not some individual accolade, so adapt these forms as needed to suit your company's needs, give credit where credit where credit is due and get into compliance. After all, believe it or not, the government does not want to cite you. They really want you to comply with the safety aspects for the safety of everyone, not just to meet the "requirements."