Today I will write to Minister of Health, Aaron Motsoaledi, to request that he necessitate the Office of Health Standards Compliance (OHSC) to review and strengthen the infection control curriculum and delivery at hospitals and clinics – specifically medical waste management – to reduce the risk of patients, employees and visitors contracting disease in health care settings.
Infection control is a practical sub-discipline of epidemiology concerned with preventing healthcare-associated infections such as TB within the confines of a particular health-care delivery system. Infection control addresses factors related to the spread of infections within the healthcare setting (whether patient to patient, patients to staff, staff to patients or among staff), including:
- prevention via hand hygiene/hand washing, cleaning/disinfection/sterilization, vaccination and surveillance;
- monitoring/investigation of demonstrated or suspected spread of infections within a particular health-care setting; and
- managing the interruption of outbreaks.
DA visits to hospitals to date in the Free State, Eastern Cape, Gauteng and the Northern Cape revealed extraordinary deficiencies in the healthcare infection control system and specifically in the poor quality of the medical waste physical infrastructure, a shortage of professional staff trained in infection control and grossly improper staffing – cleaners rather than nurses were often the ones inappropriately used to separate hazardous waste.
Responses to questions I posed to industry insiders in the medical waste removal business reveal an unregulated education and training system, little to no management accountability, no independent quality assessment and a slapdash approach to enforcing rules and standards in a world that can least afford it because of the high risk they pose to health.
Question 1: Who designs the infection control curriculum for the separation, storage, removal and disposal of medical waste?
Answer: The curriculum is assembled by individual medical waste removal companies (there are six main companies with provincial tenders). For some it is guided by the National Core Standards and the Hazardous Biological Agents (HBA) Regulations 2001 but the material, again for some, is mostly derived from the SANS 10248-1 guidelines: ‘Management of healthcare waste – Part 1 Management of healthcare risk waste from a healthcare facility.’
Comment: There is no standard and nationally authorized infection control curriculum used for education and training in infection control.
Question 2: Where is it specified whom it is that should be trained?
Answer: HBA Regulations specify that anyone involved with Heath Care Risk Waste (HCRW) be trained Core standards suggests that cleaners and hospital staff can be included in the training but at an appropriate level.
Comment: There is no authorized specification of who is to be trained. Laissez faire.
Question 3: Where is it specified as to who trains?
Answer: There is no specification as to who must train, but the onus lies with the employer to create a safe environment for the employee and thus provide training to any hazard.
Comment: Education and training entities are uncertified.
Question 4: Is there ongoing and continuous assessment of the quality of training?
Answer: The quality of training is usually visible in the staff commitment to HCRW management at facility level. The training material is sourced from the SANS guidelines, thus the quality of material should be standard. It is impossible to judge quality of the actual training as many people offer it.
Comment: There is no organized system of continuous quality assessment.
Question 5: Who does the assessment? Where is it specified who the assessors must be? Where are assessors trained?
Answer: Some companies audit the facilities that they service and the tool for it is based on recommendations from the SANS 10248 guidelines. Hospitals may also have their own tools but this should be guided by the SANS guidelines. The National Core Standards also have a mini audit available to facilities.
Comment: Companies and hospitals are self-assessing, if assessing at all. There are no independent quality assessments.
In sum, there is no approved standardised curriculum or proper training, no management accountability and no independent assessment when it comes to infection control in health-care settings. Specifically, medical waste management is ad hoc, laissez fare and fragmented. Given what’s at stake, this is utterly unacceptable.
The regulations that govern medical waste removal are very strict, for good reason. Hospitals and clinics must segregate waste into five categories: (1) human or anatomical waste; (2) infectious non-anatomical waste; (3) sharps such as needles and syringes; (4) chemical, including pharmaceutical waste; and (5) general waste. The education and training system for infection control should be equally strict and rigorous.
Health Care Risk Waste (HCRW) committees appear to be put together when healthcare facility managements feel like it. Each health-care facility should have a HCRW Committee that organizes awareness events and training, but this is not commonplace.
The DA will continue to pursue this issue until public confidence in the biosafety of our health-care institutions is secured.