Standard Precautions Training in Adult Family Homes (AFHs)
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Date: July 25, 2006 DDES-BQA 06-017
To: Adult Family Homes AFH 06
From: Kevin Coughlin, Chief, Assisted Living Section
Via: Otis Woods, Director, Bureau of Quality Assurance
The purpose of this memo is to clarify the Standard Precaution training
requirements for state-licensed Adult Family Homes (AFHs). Recently,
Assisted Living Section staff have reported numerous inquiries from
providers asking whether the Standard Precautions training required for
AFHs must be a Department-approved Community-Based Residential Facility (CBRF)
training program. The following information elaborates on the training
requirements of Occupational Safety and Health Administration Standard 29
(OSHA Standard 29) referenced in Wis. Admin. Code § HFS 88.04(2)(h), and
provides guidance to AFH providers about the required Standard Precaution
training when a Department-approved CBRF course is not used.
Applicable Codes Related to Training:
Wis. Admin. Code HFS 88.04(2)(h) states: "The licensee and all
service providers involved in the operation of the adult family home shall
comply with the universal precautions contained in the U.S. Occupational
Safety and Health Administration Standard 29 CFR 1910.1030 for the control
of blood-borne pathogens."
OSHA Standard 29, which addresses the control of bloodborne pathogens,
is found at the following link:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table
=STANDARDS&p_id=10051
The Department expects AFHs to comply with all areas of OSHA Standard
29, except § 1910.1030(e), which applies to HIV and HBV research
laboratories and production facilities. The OSHA Standard 29 training
requirements are found at:
- 29 CFR §§ 1910.1030(g)(2)(i)-(iii), and (vii)(A)-(K)
Requirements:
1. Section HFS 88.04(2)(h) requires AFHs to comply with OSHA Standard
29 related to the control of bloodborne pathogens. This OSHA Standard
requires an employer to provide annual training in the prevention of
bloodborne infections to all staff who may come in contact with the blood
or other potentially infectious material from a resident.
2. AFH staff are not required to complete a CBRF Standard Precautions
training course; however, AFH staff are required to receive Standard
Precautions training from an entity knowledgeable in the area of standard
precautions.
3. The following training programs meet the requirements of § HFS
88.04(2)(h):
- All Department-approved CBRF training programs;
- Training provided by a Department-recognized training entity (e.g.,
technical college, university, infection control practitioner, etc.);
- Training provided by home health agencies, hospitals, nursing homes,
and public health agencies, etc.;
- Training provided by a qualified third-party trainer or consultant;
and
- Any training program that includes all of the required elements
identified in OSHA Standard 29.
4. Documentation of training: Wis. Admin. Code § HFS 88.09(2)(a)8.
requires AFHs to maintain records of successful completion of OSHA
Standard 29 training.
NOTE: This memo addresses OSHA Standard 29 training requirements
only. This memo does not address other OSHA requirements found in the
federal regulation pertaining to bloodborne pathogens, and, therefore,
does not relieve an AFH provider from complying with the other applicable
OSHA Standard 29 requirements.
Please contact your Assisted Living Regional Director if you have any
questions about this memo.
SB/SM/caa
cc: Laurie Arkens, BQA/PRQI
Sherri Olson, BQA/PRQI
Doug Englebert, BQA/PRQI
Debra Bursinger, OLC
Jesús Garza, OLC
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