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|  | March 9, 2004 Angela Presson, MD, MPH
U.S. Dept. of Labor - OSHA
Office of Occupational Medicine
200 Constitution Avenue, NW
Room N 3657
Washington, DC 20210 RE: Safety and health information bulletin (SHIB): Managing Bacillus anthracis contaminants in health care facilities. ACTION: Request for review and comment. The American Association of Occupational Health Nurses, Inc. (AAOHN) is pleased to provide comments on OSHA's SHIB: Managing Bacillus anthracis contaminants in health care facilities. Below please find AAOHN's general comments, along with specific feedback. General Comments -
AAOHN supports the agency's efforts to develop a safety and health bulletin for Bacillus anthracis contaminants exposure in health care facilities. With the potential of bioterrorism and the use of biological hazards such as anthrax, disaster preparedness plans must include exposure potential and/or entry into the facility, use of personal protective equipment (PPE), and decontamination strategies. We would therefore hope that this SHIB document would be updated periodically as environmental changes warrant. -
The Association recommends using patient/client in place of patient. Different facilities and locations use one vs. the other or use them interchangeably. AAOHN values OSHA's efforts to assist health care employers and employees with safety and health information on Bacillus anthracis. However, the CDC reference (www.cdc.gov/ncidod/hip/ISOLAT/isolat.htm) used to support the skin hygiene and protection measures was last updated in 1997. There are more recent resources available from OSHA and CDC. Although precautions for bloodborne pathogens (BBP) and Bacillus anthracis may be the same, the document should address Bacillus anthracis precautions and not just BBP precautions. Prior to the 2001 anthrax attacks, the position was that the spores would tend to clump and not remain in the air. But, if the physical state were altered to defy common knowledge, can we be sure that any level of engineering or PPE protection will be adequate in all circumstances? Therefore, the Association would like to comment on the following specific areas: -
Page 1, Introduction, 1st paragraph: Recommend the following edit, replace "personnel working in front-line health care facilities such as emergency departments" with "health care worker/provider working in front-line health care facilities such as hospital emergency rooms and/or emergency clinics&." to be consistent with the other OSHA documents. Health care worker/provider also references professional and non-professional emergency employees. -
Page 1, Introduction, 2nd paragraph: How would someone know if decontamination was successful? Just because decontamination, i.e., removal of clothing, showering, etc occurred or was attempted, is it assumed that it was successful? Once thoroughly decontaminated, an individual should pose no greater risk of transmission, but with genetic engineering one cannot be totally sure that anthrax will act like anthrax. Does this pose any further decontamination issues? Also, the use of bio-colored/bio-hazard bags should be mentioned. -
Page 1, Handwashing: No mention was made of anthrax contact, just bloodborne pathogens. Suggest introduction sentence to read something like, "Basic handwashing remains the single most important measure of infection control, therefore, hands are washed (or hand hygiene used) after ALL occupational exposures, between procedures and patient/client contact, and after removing gloves." -
Page 2, Gloves: Type of gloves specific to anthrax was not mentioned in the document although CDC mentioned that gloves reduce hand contamination by 70 to 80 percent. According to (www.osha.gov/SLTC/bioterrorism/anthrax/faqs.html), "Nitrile or vinyl gloves will protect workers from cutaneous anthrax exposure. Latex gloves offer protection similar to nitrile or vinyl, but can result in sensitization or elicit allergic reactions in a small percentage of people." This should at least be mentioned. NOTE: The use of gloves does not eliminate the need for hand washing/hand hygiene. -
Page 2, Eye protection: For consistency, suggest first sentence to read, "A mask and eye protection or face shield are worn to protect mucous membranes of the eyes, nose, and mouth while performing procedures and patient/client care activities that may result from occupational exposures." -
Page 2, Gowns: Gowns are worn to prevent soiling of clothing during procedures, and to prevent the possibility of agent transmission, not just for protection from BBPs. -
Page 2, Respiratory protection: According to CDC, "existing recommendations for protecting workers from biological hazards require the use of half-mask or full facepiece air-purifying respirators with particulate filter efficiencies ranging from N95 to P100 as a minimum level of protection." Therefore, this needs to be stated. Appropriately, the issue of proper "fit-testing" is addressed. The Association appreciates the opportunity to respond to the safety and health information bulletin for Bacillus anthracis contaminants in health care facilities because health-care providers, i.e., hospital emergency, occupational health, and public health departments/clinics, should be alert to illness patterns and diagnostic clues that might indicate an unusual disease outbreak associated with intentional release of biological agents such as anthrax. As always, we will continue to lend our input and assistance to OSHA to facilitate safe and healthful workplaces and communities. Sincerely, Susan A. Randolph, MSN, RN, COHN-S, FAAOHN
President CC: AAOHN Board of Directors
Ann Cox, Executive Director | |
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