You may think, “Well, this doesn’t apply to me because I don’t do any procedures in my office.”  However, this is a misconception.  Do you give injections, or treat patients with infections or possible communicable diseases?  If yes, then infection prevention applies to you, too!  Virtually all providers must follow CDC (Centers for Disease Control and Prevention) infection control and blood borne pathogen guidelines.  In addition, NJ requires that all licensees must comply with federal OSHA (Occupational Health and Safety Administration) regulations, as well as CDC guidelines concerning infection control practices.   
Here are some important infection prevention strategies:
  1. SUDs (Single Use Devices) – SUDs are devices that the manufacturer has labeled for single-use only on a single patient during a single procedure. SUD reprocessing, meaning that the original device has been previously used on a patient or has been subjected to additional processing for use again on another patient(s), has significant risks and can be dangerous.   In August 2000, the FDA released a guidance document on SUDs reprocessed by third parties or hospitals.  The FDA states that these entities will be considered “manufacturers” and regulated in the same manner.  A reused single-use device will have to comply with the same regulatory requirements of the device as when it was originally manufactured.  These requirements are very complex.  Therefore, unless there is strict compliance to the FDA guidance document, then it is strongly recommended that SUDs should not be reprocessed in a provider’s medical office. 
  2. Safe Injection Practices – Syringe reuse, misuse of medication vials, and drug diversion/tampering have resulted in outbreaks where more than 150,000 patients had to seek testing for bloodborne pathogens, such as Hepatitis B, C and HIV.  The NJ Department of Health, in conjunction with the CDC, have issued guidance on safe injection practices to at least include:
    1. Performance of proper hand hygiene
    2. Aseptic technique in all aspects of parenteral medication administration, medication vial use, injections and glucose monitoring procedures.
    3. Do not reuse a syringe to enter a medication vial/ampule or container, even if the needle is changed.
    4. Never use bags or bottles of intravenous solution or fluid administration sets as a common source of fluids or administration for multiple patients
    5. Use a single dose vial one time for one patient only.  Never use a single-dose vial or ampule for multiple patients.  If a multi-dose vial is used, it should be used for one patient only and then discarded.  Each entry must be with a new, unused sterile needle and syringe, even if the vial is dedicated to a single patient. 
    6. Dispose of used needles immediately in an approved sharps container at the point of care.  Do not recap, bend or remove needles.
    7. Adhere to all federal and state requirements for protection of healthcare personnel from exposure to bloodborne pathogens and other infectious materials.
  3. Exposure Control and Infection Prevention Program and Plan – In addition to CDC Guidelines, medical offices need to comply with OSHA’s Bloodborne Pathogens and Hazard Communications Standards, which apply to the protection of workers.  This necessitates a written Exposure Control Plan (ECP) that includes precautions; worker vaccinations; work practice controls, including for bloodborne pathogens and use of standard precautions; PPE (Personal Protective Equipment); housekeeping; cleaning and disinfection; laundry; disposal of hazardous and soiled material; staff training; as well as other components.  These requirements apply to all employers, regardless of the number of staff employed.  This is in addition to the CDC’s Infection Prevention Guidelines, which are designed to protect patients.  At a minimum, it includes infection prevention policies and procedures; training in bloodborne pathogens and standard precautions; hand hygiene; respiratory hygiene; injection safety; measures to institute if there is an exposure or outbreak; surveillance and reporting; and much more.   
Conventus members enjoy the benefits of resources available to help your practice establish proper infection prevention protocols and exposure controls meeting the many OSHA requirements and CDC guidelines.  Conventus has arranged for discounted member pricing from an outside strategic partner to develop an Exposure Control and Infection Prevention Program and Plan tailored to your office’s needs, as well as for training your staff.  In addition, Conventus has sample templates and checklists for housekeeping, environmental rounds, infection control/bloodborne pathogens, and more.   Please contact the Practice Resources Department for more information at 877-444-0484, x7466.