National Nurses United

6 www.NationalNursesUnited.org OSHA is considering the need for a standard to ensure that employers establish a compre- hensive infection control program and control measures to protect employees from exposures to infectious agents that can cause significant disease. Although the Bloodborne Pathogens standard has been very effective in protecting workers, it does not address infectious diseases transmitted by other routes (e.g., contact, drop- let and airborne). In addition, OSHA believes that a standard is needed because transmis- sion-based infection control guidelines, though readily available, are not consistently followed. The Agency has thus far published an Infectious Diseases Request for Information (RFI), held stakeholder meetings, conducted site visits, and completed the SBREFA process. Feedback from these sources helped the Agency to further refine its development of a Notice of Proposed Rulemaking (NPRM) regarding an Infectious Diseases standard. In the Spring, 2017 Regu- latory Agenda the ID NPRM has been placed under long term action. California's state OSHA plan, Cal/OSHA, passed their Aerosol Transmissible Diseases Standard (8 CCR 5199) in 2009. This Standard sets a strong model for the nation to follow, requiring health care and other employers to protect employees from exposure to droplet and aerosol transmissible diseases. Cost-Benefit Analysis, Or Why Employers Don't Prevent All Infectious Disease Exposures The CDC became interested in studying health care-ac- quired infections in the early 1970s. The CDC first estab- lished the National Nosocomial Infections Surveillance system, which was shortly followed by the CDC's absorp- tion of the National Institute for Occupational Safety and Health (NIOSH). In 1974, the CDC commissioned the first ever comprehensive national health care-acquired infections surveillance study: the Study of the Efficacy of Nosocomial Infection Control (SENIC). The results were analyzed and widely publicized for the first time in the early 1980s. The purpose of the SENIC study was to provide a scien- tific basis for evaluating the variety of infection surveil- lance, prevention, and control programs that had been implemented by hospitals. The principle researchers determined that at that time just 0.2% of U.S. hospitals had programs that effectively reduced all major types of health care-acquired infections. Researchers also determined that at least one third of all health care-ac- quired infections included in the study could have been prevented if hospitals were to implement simple admin- istrative measures. These data showed that hospitals neglecting infection prevention were putting a higher number of their patients at risk for preventable infection. With the release of the SENIC report in 1974, the cost of infection prevention measures was already at the fore- front of the discussion. Within the first few paragraphs of this major publication, the authors acknowledge that the costs of many of the initiatives thought to be effective in controlling and reducing health care-acquired infections were primary in their consideration. The authors dis- cussed how many of these infection prevention measures could not be charged to insurers or patients due to their preventative nature. The authors observed, "it seemed inevitable that, as fiscal pressures on hospitals increased, these preventive programs would receive progressively lower priority in the operating budgets of hospitals." And even before the SENIC report, the CDC's first edi- tion guidelines on protecting health care workers and patients from infectious diseases suggested that hospital costs should be prioritized over individual health. The manual's preface explains why no previous guidance for health care providers had been published. Because "1) [earlier] isolation recommendations are too abbreviated to serve as an adequate guide for hospital personnel, or 2) the recommended practices are much too costly, com- plicated, or time-consuming to be effectively utilized," See Figure 3. Figure 3: First CDC Isolation Guidelines, Published 1970 The CDC guidelines state that there exists conflicting evidence for certain disease transmission patterns. In instances where there is more than one known route of transmission or where additional routes may be rare or only theoretically possible without documented cases, the CDC guidelines claim that "the type of isolation recom- mended is the one that considers the common route of transmission." These values are in direct opposition to the precaution- ary principle. The precautionary principle is an ethical position that should be universally at the heart of all policy, guidelines, and regulations. This principle states that protections should be designed to ensure health is preserved from all unknown potentially adverse effects of exposure to phenomena too new or complex to have been sufficiently understood by science. Or, when facing a sit- uation where the science is unclear, protect to the highest level, protect for the worst case scenario.

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