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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: 
Australian Podiatry Association
Specific Questions
1. Introduction: 

Whilst we recognise that these guidelines cover all areas of healthcare ranging from hospitals to office based practices  the majority of our members practice in an office based environment(s) and can have a hard time interperting and putting in to practice the guidelines. The interpretation can be conflicting. We have had instances where different bodies would interpert these guidelines differently. For example auditors appointed by AHPRA and the RACGP. 


Asking for clarificaiton for podiaty specific issues.

3. Standard and transmission-based precautions: 

3.1.6  Reprocessing of reusable instruments and equipment

The opening paragrah refers to AS/NZ 4817 however it does not include AS/NZ 4815. We would like to see both standards included in the opening statement as this could be mis interperated that AS/NZ 4815 is not to be utilised for reprocessing.

Manual Cleaning

Cleaning is done manually for fragile or difficult-to-clean instruments and in areas without automatic units. Clarity may be needed on this statement in relation to compliance with AS/NZ4817 

3.1.10 Handling of linen

We would like clarificaiton  in a podiatric scenario on:

If items such as low linting towels used for the drying of ­clean instruments before sterilisation can be washed  in a domestic washing machine or if these items must be washed in accordance with AS/NZS4146 (in other words sent to an industrial laundry)?

and if so

Can these be taken home to be washed in a multi-purpose domestic washing machine, or must the machine be specifically for clinic washing only?

3.2.4 Airborne Precautions

There is little clarity in documentation around the expectations for protection from nail dust which may be generated from drilling/filing nails, especially with electric drills. Podiatrists wear masks as part of their PPE when drilling. The presumption from the NHMRC is that masks of P2 or N95 rating to AS/NZS standard 1716 are the appropriate precaution to take. Would masks compliant with AS/NZS 1716 also meet these requirements?

There has even been some suggestion that patients should wear masks during nail drilling process.


4. Organisational support: 

4.2.5 Exposure prone procedures, Table 26,

Clarity is sought on the exposure prone procedures listed in the table under podiatry. General podiatrist often undertake simple routine surgery such as phenol and alcohol nail surgery (chemical matrixectomies ) and are not included in this section. Only podiatric surgeons have been listed.

4.6 Influence of facility design on healthcare associated infection

Seeking clarification on:

appropriate work place design: separation of procedural and cleaning areas. with reference to insrument reprocessing areas. This has been an area of conflict between AHPRA appointed auditors and other key advisory organisations. Everyone seems to have a different undertanding of what separation means. 

4.6.2 Mechanisms for Influencing Healthcare associated infection through environmental design

Clarification is sought on the statement:

As well as being installed in all patient-care areas, hand-hygiene facilities should be placed in all areas where careful attention to hygiene is essential, such as kitchens, laundries, pharmacies, laboratories and staff amenities areas (e.g. bathrooms, toilets and change rooms). This also includes in specific settings such as treatment/procedure rooms [340].

Does this mean an alcohol based product dispenser is an appropriate hand hygiene facility? Or does a specific hand washing sink have to be installed in the treatment/procedure room?

6. Appendix 2: 

Chlorhexidine resistance

The podiatry profession has noted the concerns raised over chlorhexidine resistance and anaphalaxis and will be communicating this to our profession. 

Page reviewed: 24 September, 2019