How to Don and Doff a Lab Coat

OSHA requires that all lab employees be able to demonstrate how to don and doff a lab coat. For written instructions go to the CDC link at: http://www.cdc.gov/ncidod/dhqp/pdf/ppe/ppeposter148.pdf

Potential Exposures During Proficiency Testing

Although this was reported over a year ago by the CDC in its MMWR, it bears repeating. Are your procedures up to date?

On November 27, 2007, CDC was notified by New York State Department of Heath (NYSDOH) officials of potential Brucella abortus RB51 (RB51) exposures to laboratorians at a state laboratory from an isolate used in a recent Laboratory Preparedness Survey (LPS). RB51 is an attenuated vaccine strain of B. abortus used to vaccinate cattle against brucellosis; human illness is known to have resulted from RB51 vaccine--related exposures (1). The LPS is a voluntary proficiency-testing program developed jointly by the College of American Pathologists (CAP), Association of Public Health Laboratories (APHL), and CDC. The program is designed to exercise protocols for "rule-out" or "referral" of potential bioterrorism agents. During the October--November LPS exercise, 1,316 laboratories participated. Written LPS instructions instructed laboratories to handle and manipulate all samples under a Class II Biological Safety Cabinet (Class II BSC), using Biological Safety Level 3 (BSL3) primary barriers. The reported exposures occurred when an LPS RB51 specimen was mislabeled as a routine patient specimen and was submitted by an LPS participating laboratory to the New York state bacteriology laboratory. As a result, routine benchtop procedures were used to handle the isolate by NYSDOH lab personnel outside of the Class II BSC, resulting in 24 laboratorians with potential exposure to RB51. After this incident, NYSDOH contacted all New York LPS-participating laboratories to determine whether other exposures had occurred. Of the participating laboratories contacted, 80% had performed at least one procedure outside of the Class II BSC, despite the LPS written instructions outlining appropriate biosafety handling practices.

CDC was consulted and recommended that those laboratorians who conducted procedures with exposures placing them at high risk receive postexposure prophylaxis. The findings in New York also raised concern that participating laboratories outside of the state might not have followed all prescribed biosafety instructions, possibly exposing other laboratory personnel to RB51. CDC is collaborating with CAP, APHL, and public health officials to 1) determine exposure risk in participating laboratories, 2) provide interim guidance on risk assessment and postexposure prophylaxis recommendations, 3) identify any illnesses associated with potential RB51 exposures among laboratorians participating in the LPS, and 4) identify follow-up actions and the need for additional guidance (e.g., education or training).

During December 3--10, 2007, CDC took steps to provide information regarding the RB51 incident to public health officials. State public health officials were notified via a broadcast e-mail and through an alert on the Epidemic Information Exchange (Epi-X). National conference calls were conducted with state public health laboratory directors and state epidemiologists to provide interim guidance on risk assessment and postexposure prophylaxis recommendations. Formal notification was sent by overnight letter from CAP to all participating LPS laboratories. Laboratories were recommended to review their biosafety practices during handling of RB51 specimens and report breaches in biosafety practices to their local public health officials for risk determination and recommendations. A set of questions was distributed to facilitate review of biosafety practices used during the LPS to identify potentially exposed persons. Laboratories were advised to ensure their ability to comply with standard biosafety protocols as defined in Biosafety in Microbiological and Biomedical Laboratories, 5th Edition* and to take steps to avoid specimen handling errors. To date, CDC has not learned of any illness consistent with brucellosis in any laboratory staff member potentially exposed to an LPS RB51 isolate.

For information regarding risk assessments and postexposure prophylaxis recommendations for potentially exposed persons, laboratories can contact state or local health officials. Information regarding B. abortus RB51 is available at the CDC Bacterial Zoonoses Branch, telephone 404-639-1711, or the CDC brucellosis website.† Public health officials can access updated information and risk assessment tools in Epi-X forum, "Brucella abortus/RB51 Exposure." Specific questions regarding the LPS can be directed to the CAP website§ or hotline, 800-443-3244. Questions regarding laboratory biosafety procedures can be directed to the CDC Laboratory Response Network, by e-mail, lrn@cdc.gov, or telephone, 866-576-5227.

Rapid HIV Testing Following a Needlestick

The following question was submitted to OSHA:

Is it a violation of 29 CFR 1910.1030 for a medical facility subject to OSHA authority not to perform "rapid HIV antibody testing" on a source individual after an exposure incident?

Here is the reply from OSHA's Richard Fairfax at the Office of Health Enforcement:

Reply: As you may know, the bloodborne pathogens standard provides that "the source individual's blood shall be tested as soon as feasible" after an exposure incident and after consent is obtained [29 CFR 1910.1030(f)(3)(ii)(A)]. At the current time there are at least four FDA-approved tests available for "rapid HIV antibody testing," which usually can confirm negative HIV status in less than an hour after blood is drawn from a source individual. They are widely available, easy to use, and inexpensive. Standard enzyme immunoassay (EIA) testing can take a much longer time, especially if facilities to perform the tests are not available locally. Therefore, an employer's failure to use rapid HIV antibody testing when testing as required by paragraph 1910.1030(f)(3)(ii)(A) would usually be considered a violation of that provision. The use of rapid HIV antibody testing is supported by the current CDC recommendations for HIV post-exposure prophylaxis (PEP) in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis, published on September 30, 2005. The CDC states on page 7 that having a "rapid HIV test could result in decreased use of PEP and spare personnel both undue anxiety and adverse effects of antiretroviral PEP." The document goes on to note on page 8 that "rapid HIV testing of source patients can facilitate making timely decisions regarding use of HIV PEP after occupational exposures to sources of unknown HIV status." Current guidance on the management of HBV and HCV exposure and PEP, as well as guidance for evaluation of the exposure source, is also contained in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV and HIV and Recommendations for Postexposure Prophylaxis (June 29, 2001), Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.