Based on the risk level identified by the divisional risk assessment, certain divisions will require a formalized infection control program incorporating all program elements identified below. Other city divisions, based on the nature of work performed and its associated risk, will require inclusion of only some program elements.
Elements to be considered in developing and implementing an infectious disease prevention and control program for the given risk include the following:
- Hand Hygiene Program - to prevent the spread of infections and reduce their incidence
- Preventive Measures/Controls - to eliminate or minimize employee exposure to infectious agents and diseases
- Written Safe Work Procedures & Exposure Control Plans readily and practicably accessible
- Hazard Communication - to provide information and instruction to workers (initially and ongoing) on infectious agents/disease hazards, safe work practices and control measures
- Incident/Illness Reporting
- Documentation and Recordkeeping - to provide necessary records of compliance as well as to track program changes
- Regular Program Review – to review effectiveness of program elements at least annually, and update as necessary
Hand Hygiene Program
Hand Hygiene is recognized as the most important strategy for reducing the spread of infections and illnesses. Hand washing and /or use of alcohol based hand rubs/sanitizers is the action carried out to protect one's self and others.
A hand hygiene program includes hand washing instructions/signage, selection of appropriate hand hygiene agent (i.e. soap, sanitizer), ready access to hand hygiene agents (e.g. at point of care in health care settings or other accessible locations).
Resources to assist with development of a hand hygiene program are included in the Resource Tool Kit.
Preventative Measures and Controls
The risk of exposure to infection and strategies to control these risks vary with work performed and work setting. Based on the identified risk, consideration should first be given to preventing the exposure by modifying the task/job that exposes the worker to the source if possible. In situations where the exposure cannot be eliminated, the risk of exposure needs to be controlled giving consideration to the following:
- Environmental controls
- Engineering controls (e.g. ventilation, isolation rooms with dedicated exhaust, enclosed processes, barriers)
- Placement and spacing of materials, including beds in living accommodations
- Point-of-care sharps containers
- Housekeeping Measures
Administrative Controls & Practices
- Cleaning/disinfection of surfaces
- Proper disposal of contaminated materials
Personal Protective Equipment (e.g. Gloves, gowns, eye and face protection, respirators – N95 or other). Use, maintenance care, fit and replacement of personal protective equipment is to be addressed
- Respiratory Etiquette, Social Distancing or Distancing from source through use of tools
- Immunization Programs
- Healthy Workplace Policies
Where practicable, the infection prevention/control plan should give preference to engineering controls. The required number of controls increases with the level of risk.
See the Resource Tool Kit for guidance on a number of control and work practices referenced above.
Written Safe Work Procedures/Exposure Control Plans/Infection Control Plans
Any division that identifies risks of employee exposure to infectious agents/diseases are to develop and implement written safe work procedures, exposure and infection control plans that will protect employees from exposure and/or adverse effects (e.g. divisions whose employees work with persons with infectious diseases/illnesses, who are in contact with sewage, and those who are at risk of needle stick injuries.
While such comprehensive procedures/plans are not required in low risk workplaces (e.g. office environment), education, instruction and training should be used to adequately address worker protection.
For certain settings such as Health Care, there are specific regulations such as "The Health Care and Residential Facilities Regulations" under Ontario's Occupational Health and Safety Act requiring employers to have in place written measures and procedures for the control of infections.
Ministry of Labour inspectors, during visits to City work locations, have demonstrated that written measures and procedures for the control of infections are also expected in other divisions that perform health care or health care-like functions (e.g. EMS, Fire, SS&HA, Children's Services). It is important that these measures and procedures sre readily and practicably available to workers who require them and for MOL inspectors, should they be requested.
This expectation also appears in other jurisdictions. Worksafe B.C., in its document entitled " Controlling Exposure: Protecting Workers from Infectious Disease" broadens these expectations to workplaces including, but not limited to, the following:
- Nursing homes
- Home healthcare
- Dentist's offices
- Ambulance and paramedic services
- Fire and rescue and lifesaving services
- Research laboratories
- Daycare facilities
- Animal hospitals
- Wherever occupational first aid attendants are designated
Examples of written Safe Work Procedures for various activities and workplace settings are included in the Resource Took Kit (e.g. Clean Up of Blood Spills; Cleaning up Pigeon/Bird Droppings; Handling/Disposal of Sharps; Waste Water Handling; etc.)
Workers are to be provided with information and instruction with respect to:
- The risks associated with infectious diseases to which they may be exposed
- Principles and components of Routine Practices as well as additional measures that may be needed to prevent transmission, as appropriate
- Hand hygiene, including the use of alcohol-based hand rubs and hand washing
- Appropriate cleaning and/or disinfection of equipment, supplies and surfaces or items in the work environment
- Proper disposal methods for contaminated materials and equipment
- Proper use of tools and equipment to prevent and/or minimize contact and transmission
- Use, care donning/doffing, limitations, fit and maintenance of PPE
- The safe and appropriate use of cleaning chemicals for workers involved in cleaning the workplace
- Individual staff responsibility for keeping clients/ residents, themselves and coworkers safe
- Conducting individual risk assessment before each interaction with a client/resident or their environment in order to determine which interventions are required to prevent transmission during the interaction, recognizing that a client/resident’s status can change
- The importance of reporting a work-related exposure to an infectious agent or illness
- The importance of vaccinations and the division's expectations with respect to vaccinations (e.g. types of recommended vaccinations). Further information on immunization is available in the resource took kit.
All staff training/instruction needs to be documented, referencing information content, type of training (awareness, practitioner level, etc), date, location and staff who attended.
Reporting of incidents and illnesses
In the event that an employee seeks health care or loses time from work as a result of a work-related exposure to an infectious illness or agent, the employee must report the incident to the supervisor. If an employee seeks health care as a result of work-related exposure to an infectious disease or agent or loses time from work, a claim must be filed with the Workplace Safety and Insurance Board.
There are additional reporting requirements if the City is advised by or on behalf of a worker that the worker has an occupational illness or that a claim in respect of an occupational illness has been filed with the Workplace Safety and Insurance Board. The City shall give notice in writing, within four days of being so advised, to:
- the MOL
- the joint health and safety committee or a health and safety representative
- the union, if any
These notices shall contain such information and particulars as are prescribed in regulations made under the Occupational Health and Safety Act.
[Note: The requirement to submit a report does not necessitate laboratory confirmation of an occupational illness.]
Divisions are reminded that outbreaks may also be reportable to the Ministry and Health and Long-Term Care.
Documentation and Recordkeeping
To provide for an effective program, the hazard, risks and measures to control the risks need to be communicated consistently and available in writing. To assist in this regard, the following documentation is needed:
- Divisional Risk Assessment identifying date of completion
- Infectious Disease Prevention and Control Plan - outlining the program elements for the identified risk level
- Safe work procedures/ written exposure control plans/written infection control plans
- Training/Hazard Communication/Education- — keep track of who was trained, when the training took place, and what was included.
- Workplace inspections
- Health and safety meetings
- Investigations that take place after exposure incidents
- Records of exposed workers and any health monitoring required
- Immunization documentation, where mandated
These records can be especially useful for demonstrating compliance with occupational health and safety legislation, and tracking changes. Records should be retained according to retention period specified by legislative requirements where applicable, and/or until superceded by updated records.
Regular infectious disease program review
Review infectious disease prevention and control programs annually, and update as necessary. During this process, consult with the joint health and safety committee or worker health and safety representative.
Resource Tool Kit
Resources to assist with the development and implementation of various elements of your divisional infectious disease prevention and control program are available in the Resource Took Kit.