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Draft revised Australian Guidelines for the Prevention and Control of Infection in Healthcare submission

Personal Details
This submission reflects the views of
Organisation Name: 
Specific Questions
3. Standard and transmission-based precautions: 

Recommendation 24 Comments

Section 3.2 and 3.2.2 (previously known as Section B2.2)

These two sections related to contact precautions and instructions to healthcare workers (HCWs) on donning non-sterile gloves and hand hygiene. 

Concerns: Our concerns relate to the instructions to HCWs:

  1. “perform hand hygiene;

  2. put on gloves and gown upon entry to the patient-care area;

  3. ensure that clothing and skin do not contact potentially contaminated environmental surfaces;

  4.  remove gown and gloves and perform hand hygiene before leaving the patient-care area.”


We made a video to demonstrate to NHMRC where these instructions cause contamination of the patient-care area, patient and potential introduction of pathogens into a sterile area (ie via an intravascular device). We have indicated in the video (can’t attach it but can send it through email on request) where the four NHMRC instructional guide (listed above) are in breach of infection prevention and control. If the HCW were to be ungloved in the video the red crosses in the video would indicate a hand hygiene opportunity. As the HCW is gloved upon entry she is now incapable of complying with My Five Moments for Hand Hygiene”.

The second point of the above four points associated with the Section 3.2.2 of the proposed Guideline the HCW was instructed to don a ‘gown’ however this would have prevented her from performing an aseptic procedure which requires the HCW be bare-to-the-elbows.


We observed a common scenario of care performed on a patient under contact precautions where HCWs attempt to undertake several tasks during a single visit to the patient. The video shows the HCW performing these common tasks and even though the NHMRC guidelines will have expected the HCW to comply with the My Five Moments – which would require a change gloves and hand hygiene and donning new gloves before making contact with the intravascular device. However, this is not explicit in the old and proposed Guidelines/poster. HCWs should be given an opportunity to perform a risk assessment of the expected tasks to be undertaken. We have trialled a modified contact precautions and produced a poster (can’t attach it but can email it on request). The Guidelines/poster would benefit from providing explicit instructions that understand the multiple tasks undertaken by a HCW as well as providing theoretical instructions. 

We have two publications addressing this Section to improve hand hygiene around Contact Precautions and can email these on request. https://doi.org/10.1016/j.ajic.2017.08.029




  Section 3.2.3 Recommendation 27 Droplet Precautions

This recommendation fails to include evidence that droplet particles may pentrate the muscous membranes of the healthcare workers' eyes and hence require eye protection via goggles or face shield.

Gralton J, ToveyE, McLawsML, Rawlinson WD. The Role of Particle Size in Aerosolised Virus Transmission: A Review. J Infect 2011; 62:1-13 DOI: 10.1016/j.jinf.2010.11.010



Gralton J, McLaws ML. Using evidence-based medicine to protect healthcare workers from pandemic influenza: Is it possible? Crit Care Med 2011; 39 (1):170-8. doi: 10.1097/CCM.0b013e3181fa3c28

Recommendations 30 3.2.4 Airborne precautions

There is evidence (Gralton et al) that the cut point used to  categorise particles into droplet and airborne is erroneous. Gralton J, McLaws ML. Protecting healthcare workers from pandemic influenza: N95 or surgical masks? DOI: 10.1097/CCM.0b013e3181b9e8b3

There is evidence that infectious diseases (bacterial and viral) are of mixed sizes. (Gralton J, ToveyE, McLawsML, Rawlinson WD. Respiratory virus RNA is detectable in airborne and droplet particles. J Med Virol 2013;85 (12):2151-2159. doi: 10.1002/jmv.23698.). As a result healthcare workers may be better protected using faceshields and a good quality surgical mask when not performing aerolise generating procedures (AGPs) and use P2 for only AGPs with a faceshield or goggles.  

Page reviewed: 24 September, 2019