LTC Best Practices for Compliance with OSHA's Employee-Centric Infection Control Regulation: Part II

OSHA; Safety; Infection Prevention/Control
 

The previous article Infectious Disease in LTC Part 1 looked at the regulatory landscape surrounding the Occupational Safety and Health Administration’s (OSHA) oversight of infectious disease management in long term care (LTC) settings. While there isn't yet a specific infectious disease standard tailored to LTC providers, OSHA's existing standards and guidelines, coupled with forthcoming regulations, necessitate strict infection control measures. 

Implementing Best Practices 
 
Many providers have established resident-centered infection prevention and control policies. These best practices are intended to mitigate employee exposure to infectious disease, but they may already be addressed by your existing infection prevention and control policies—often employee and resident-focused infection control are two sides of the same coin that can be addressed together. 

  1. Comprehensive Risk Assessment: LTC centers should conduct thorough hazard assessments to identify potential sources of infectious disease transmission to employees. For example, facilities can assess the risk of respiratory infections by considering factors such as resident mobility, communal living spaces, and staff interaction. Based on this assessment, targeted interventions can be implemented to mitigate risks. 

  2. Engineering Controls: Employ engineering solutions to minimize the risk of exposure to infectious diseases. For instance, optimizing ventilation systems and airflow can help dilute and remove airborne pathogens. 

  3. Training and Education: Provide comprehensive training to staff on infection control protocols, including proper hand hygiene, personal protective equipment (PPE) usage, and environmental cleaning procedures. Conduct regular training sessions and drills to ensure staff competency and readiness to respond to infectious disease outbreaks. For example, conducting simulated outbreak scenarios can help staff practice effective communication, coordination, and infection control measures in real-time. 

  4. Personal Protective Equipment (PPE): Ensure that adequate PPE is available for all staff members who may encounter infectious agents. Establish protocols for PPE use, disposal, and replenishment to maintain a safe working environment. Consider implementing a buddy system or peer monitoring to ensure proper PPE adherence and provide immediate feedback or assistance when necessary. 

  5. Respiratory Protection: In addition to standard PPE, implement respiratory protection measures where airborne hazards are present. This may involve the use of N95 respirators or equivalent respiratory protection devices, as dictated by OSHA's Respiratory Protection Standard. Conduct fit testing and provide training on proper respirator use and maintenance as required by the Standard.
     

  6. Recordkeeping and Reporting: Maintain records of infectious disease incidents, employee training sessions, hazard assessments, and corrective actions taken. Implement reporting protocols to promptly notify relevant authorities of any outbreaks or significant incidents. Regularly review and analyze incident data to identify trends, areas for improvement, and opportunities to enhance infection control measures. 

  7. Utilize Available Resources: Take advantage of OSHA's resources and guidance documents to support your infection control efforts. Engage with industry associations, peer networks, and public health agencies to stay informed about emerging infectious disease threats and best practices. Collaborate with local health departments and epidemiologists to develop outbreak response plans and coordinate surveillance efforts. 

Possible Infection Control Practices in LTC Settings 

  1. Isolation and Cohorting: A LTC provider may implement proactive isolation and cohorting strategies during an outbreak to prevent the spread of infection. By promptly identifying and isolating residents with suspected or confirmed cases of COVID-19 or other infectious diseases, a center may contain outbreaks and minimize transmission within the center. 

  2. Environmental Cleaning: A LTC setting may benefit from environmental cleaning protocols, including more frequent disinfection of high-touch surfaces and communal areas. By prioritizing thorough cleaning and disinfection practices, a center may reduce the risk of surface transmission and maintain a clean and safer environment for residents and staff. 

  3. Staff Vaccination Campaigns: A LTC setting may implement comprehensive staff vaccination campaigns to increase COVID, influenza, and similar vaccination rates among employees. Through education, motivations, and on-site vaccination clinics, a facility may achieve a higher vaccination coverage rate among staff, reducing the risk of influenza or other outbreaks and protecting vulnerable residents. 

Looking Ahead 

As OSHA continues to develop and refine its infectious disease standard for health care providers, it is essential for providers to remain proactive in their approach to infection control. By implementing comprehensive policies, procedures, and training programs, LTC providers can safeguard the health and safety of both staff and residents.