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  • ACOEM Comments on CDC’s Proposed Updated Guidance for Seasonal Flu in Healthcare Settings

    July 19, 2010

    Influenza Coordination Unit
    Centers for Disease Control and Prevention
    U.S. Department of Health and Human Services
    Attn: Prevention Strategies for Seasonal Influenza in Healthcare Settings
    1600 Clifton Road, NE, MS A-20
    Atlanta, GA 30333

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine (ACOEM) welcomes the opportunity to comment on updated guidance released by the U.S. Centers for Disease Control and Prevention (CDC) on June 22, 2010.

    ACOEM applauds the guideline’s integrated approach to the protection of both patients and healthcare personnel in medical settings. Vaccination is appropriately emphasized as the most important measure to prevent influenza infection, accompanied by attention to respiratory hygiene, management of ill healthcare workers, droplet and aerosol-generating procedure precautions, surveillance, and engineering controls.

    A multi-pronged approach to vaccination healthcare workers is advocated, emphasizing provision of vaccine at no cost and during times convenient for healthcare personnel, as well as incentives, assertive educational campaigns, involvement of senior management, and use of declination statements acknowledging receipt of education. ACOEM supports strategic and assertive implementation of the methods outlined in the CDC guidance document. We would include a recommendation that immunization rates should be monitored and reported periodically to senior management.

    Implementation of respiratory hygiene and cough etiquette is a necessary strategy to reduce influenza transmission in healthcare workplaces. Healthcare personnel face elevated transmission risk when treating patients whose illnesses are not recognized at the time of triage. In such a situation the healthcare worker generally does not employ droplet precautions. ACOEM supports all facets of respiratory hygiene and cough etiquette, and advocates specifically a low threshold for the use of facemasks by visitors and patients during the influenza season as a measure to reduce the frequency of unprotected healthcare worker exposures to patients whose respiratory symptoms were not adequately recognized at time of triage. ACOEM would ask the CDC to consider including a discussion of universal use of facemasks by patients at point of initial triage as a method to be considered by medical centers during all or part of the influenza season. This was successfully employed at some medical centers during the 2009-2010 influenza season. Based on anecdotal reports, it was well accepted by patients, and associated with decreases in inadvertent unprotected exposures among healthcare workers.

    Steps for the monitoring and management of ill healthcare workers included in the guidance document are well considered and appropriate, including the adherence on the part of healthcare personnel to respiratory hygiene and cough etiquette. We would caution that a central monitoring of absenteeism by an employee health service on a daily basis is not practicable in most settings. With respect to work restriction from protected environments among individuals without fever who have respiratory symptoms, we would caution that many settings may not have access to rRT-PCR. In addition, asthma, allergies, and other conditions make this a difficult algorithm. Also on the topic of protected environments, we would recommend that the document address restriction and monitoring of visitors to such settings.

    With respect to prioritization of vaccination, ACOEM would consider that all healthcare workers are at high priority. Only in situations of vaccine shortage should institutions prioritize based on underlying high-risk conditions or nature of clinical encounters.

    ACOEM agrees with the imposition of droplet precautions for general care of influenza patients, and with the continued use of fit-tested N95 respirators and airborne infection isolation rooms for aerosol generating procedures. ACOEM recognizes that important questions remain to be answered regarding the role of aerosols in influenza transmission and advocates for continued prioritization by CDC of this important research topic, as well as of the role of respirators for protection of healthcare workers. ACOEM is also supportive of continued work to explore whether improvements in respirator design may yield improved face seal, and whether such improvements might influence current policies around annual fit testing.

    ACOEM considers the newly issued CDC guidance appropriately responsive to the workplace hazard faced by healthcare workers who care for patients with influenza, and is in general agreement with the recommendations outlined in the document.

    Sincerely,
    Eisenberg - new.png(4) 
    Barry S. Eisenberg, CAE
    Executive Director