NHMRC Public Consultations

I believe that a statement is needed to say that "Infection Control, Quality and Safety" (can put in a triangle shape go together for provision of appropriate health care delivery and a safe work environment for healthcare workers, clients, families, visitors and others

For the purposes of this paper the word patient is interchangable with the words: patient, client, healthcare worker and others that are protected by implemented measures. Infection Prevention and control is for everyone not just the patient (may need some rewording)

2.1 Other sources of transmission include: The word 'exogenous flora' needs to be added (endogenous is used but not exogenous)

Direct contact: e.g. percutaneous or mucous membrane exposure, direct care pathogens e.g. lice, scabies herpes simplex virus, faecal-oral diarrheal illnesses

droplet (pathogens often >than 5micons); examples add flu-like illnesses, and note here often droplet and contact precautionary measures are used simultaneously

airborne (pathogens often smaller than 5 microns), but aerolisation of larger pathogens can occur during procedures e.g...... Note chickenpox and measles can be spread via the contact route due to the presence of a rash/skin lesions and thus precautionary measures address both contact and airborne routes.

Transmission can also occur via vectors e.g. malaria, Zika, Ross River, Hendra etc via mosquitos which is not addressed in this paper

Standard Precautions: need to write at the start of the provided information that must be used for all persons regardless of known or suspected pathogens being transmitted via the contact, droplet or airborne routes

Standard precautions implemented by add: appropriate patient placement, occupational health and safety (e.g. appropriate staff screening and immune to vaccine preventable diseases), waste management, targeting epidemiologically important pathogens (emerging and re-emerging)

Case study measles: what about the contact risk due to contaminated environment due to skin lesions needs addressing: cleaning of the environment and used medical non-medical equipment: identifying patient list of appointments for any immunocompromised clients known to have visited the site during the infectious period; administration of immunoglobulin to high at risk immunocompromised  clients with consultation of primary health care management/Infectious Diseases

Why is "Educate infectious patients to report their infectious state prior to attending practice" considered hard this should be encouraged and implemented in all settings as possible???

Involving patients in their care: what about educating family members and visitors where appropriate and ensuring their adherence to implemented precautions: needs to be addressed and added

Hand Hygiene what are the risk: Need to add "not resticted to" when giving the examples of organisims spread via hands

PPE: Following statement what has this got to do with IC (quality or safety)??? "Inappropriate wearing of PPE (e.g. wearing operating suite/room attire in the public areas of a hospital or wearing such attire outside the facility) may also lead to a public perception of poor practice within the facility." I believe needs to be deleted or added as a tip only

This statement can be missed interpreted what about in the ward areas?? "...clothing that has been in contact with patients should not be worn outside the patient-care area.." needs rewording and e.g. theatre attire, burns attire, PPE used during transmission based precautions, etc. about the risk of bringing external contaminates into the institution and contaminating the clients and environment in these high risk areas???

Ties and Lanyards: YES but what is your recommendation?????

There is no evidence to suggest that home laundering is inferior to commercial reprocessing of uniforms [90??? What about detergent and temperature of the water and mixing contaminated clothing/uniforms with other clothes at home

Under PPE donning sequence:

Note that for surgical procedures and dentistry, the sequence for putting on PPE differs. in these situations, masks and protective eyewear are applied first prior to hand preparation. Gown and gloves are then put on. (See Section 3.4.3).

WHY???? You still want to protect your mucous membranes, so add hand hygiene again before donning masks and protective eyewear

 For gowns: covers exposed skin and protects the uniform i.e. long sleeve, gloves to cover the cuff, water proof (non-splash/spray) or water resistant if exposure to body fluid is expected/anticipated

Add when aprons are ok to be used in preference to gowns (and cost saving is not a reason!!)

Safety engineered Devices: The use of devices with safety-engineered protective features (e.g. safety or retractable devices) has been mandated in the US, France, Spain, most Canadian provinces and all EU member countries including the UK [114]. Their use is thought to have reduced the rate of incidence of needlestick injuries [115].

WHAT about Australia re this???? "At time of writing Australia......."

Needless Devices: note needs to be added re allergic reaction or exposure to cerebral spinal fluid, mucous membranes for CHG

Multi-dose vials

Add precautionary measure: preparing single doses in a pharmacy prior to distribution (as a single patient/single dose)

Sharps container: add features of an appropriate sharps container: well labelled, rigid, puncture proof, preferable wall mounted/secure that it does not fall

3.1.6 Reprocessing of reusable instruments and equipment

Define abbrev. TGA

I totally disagree with this statement as there is literature to support their use and so are recommended where possible: keyboard covers and washable keyboards that can be easily cleaned are in use, the infection control benefit of these items and optimal management are yet to be determined.

In this rapidly changing area, reprocessing standards should evolve to accommodate changes in equipment design and emerging technologies in sterilisation.; remove word should

wraps should act as an effective biobarrier during storage; remove word should

under table in section Critical
Entry or penetration into sterile tissue, cavity or blood stream: Add in storage regarding a room/area that is clean, has temperature, humity and light controls as per standards

Under Loan sets should be transported in fit for purpose containers to minimise the risk of damage. Add and contamination and injury to handlers; need to be cleaned/decontaminated as per manufacturers recommendations before returning to originating organisation for reprocessing

Steps in respiratory hygiene and cough etiquette

Hands should be washed with soap and water after coughing, sneezing, using tissues, or after contact with respiratory secretions or objects contaminated by these secretions. Should be washed or must be washed?????

Health care/social workers should also assist patients (e.g. elderly, children) who need assistance: SHOULD????? need to/are required to< are professionally/ethically bound to??

Waiting areas: clients with flu like illness "should" sit at leas t3 feet apart from others in the waiitngarea and if possible be use segrgated waiting areas and fast tracked to reduce risk of spread

When handling waste:

• apply standard precautions to protect against exposure to blood and body substances during handling of waste; wash hands following procedure

• segregation should occur at the point of generation

• waste should be contained in the appropriate receptacle (identified by colour and label) and disposed of according to the facility waste management plan

• healthcare workers should be trained in the correct procedures for waste handling

  Again the word should can be misinterpreted; replace with need to/are required to must (any of those)

  Airborne

  wearing of correctly-fitted surgical masks by coughing patients (if tolerated) prevents dispersal of respiratory secretions into the air [124] Need to write a note here: PATIENT NEEDS TO BE CLOSELY ASSESSED IF TOLERATED TO MINIMISE RESPIRATORY RISKS

   

  sECTION 6.2 Checklist of standard precautions for procedures tABLE SECTION Wound examination/dressing UNDER STERILE GLOVES

  SPELLING ERROR: DIRECT

  (✔For diract contact with wound)

  sECTION: Table no fully showing on screen: column Visitors

  #   If staff or visitor HAVE HAD chickenpox / measles in the past or vaccination for these diseases, mask, gown and gloves are not required: How are you going to screen visitors to ensure this and then if some are wearing and others are not it will cause confusion; EVERYONE needs to do the same to prevent confusion (???)

   

• should be placed in a pathology biohazard bag, and then into the specimen bucket
   

• The label should be stuck on the container immediately before the specimen is placed in the specimen bucket
   

• Larger specimens require a clear plastic bag, and should then be placed in a specimen bucket

  The word should can be misinterpreted here: change to needs to be or must be

Do not use the word SHOULD as it gives the impression that you should do something but  not compulsory unless it is optional (use must, or need to as alternatives)