By Craig B. Simonsen

The Occupational Safety and Health Administration is holding two stakeholders hearings on the occupational exposure to infectious diseases.  OSHA is considering what action, if any, the Agency should take to limit the spread of occupationally-acquired infectious diseases.

The hearings, scheduled for July 29, 2011, are to explore the possible development of a proposed rule to protect workers from occupational exposure to infectious agents either where the workers provide direct patient care, or where the workers perform tasks other than direct patient care that also have occupational exposure. These other work tasks include: providing patient support services such as housekeeping and facility maintenance; handling, transporting, receiving, or processing infectious items or wastes; conducting autopsies or performing mortuary services; and performing tasks in laboratories.

The stakeholder meeting discussions will center around several major issues:

  • Whether and to what extent an OSHA standard on occupational exposure to infectious diseases should apply in settings where the workers provide direct patient care, or where the workers perform tasks other than direct patient care that also have occupational exposure

  • 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 procedures (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.

  • 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 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.

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.  To participate in one of the July 29, 2011, stakeholder meetings, or be a nonparticipating observer, you must submit a notice of intent electronically, by facsimile, or by hard copy.