Comment from Bass, Gary; Public

The current CFR does NOT adequately address the occupational exposures and the associated risks to housekeepers working in a hospital environment (Hospital Housekeeping Aid) and therefore should be amended to specifically include this class of healthcare workers. The regulation is more focused on healthcare professionals such as physicians, nurses and those healthcare workers that come in direct contact with patients. Housekeepers working in a hospital environment have the likelihood of exposure and are exposed on a daily basis to occupational risks that are addressed in this regulation including but, not limited to the likelihood of exposure to needlesticks, blood, feces, urine and other bodily fluids. Hospital Housekeeping Aids are responsible for the cleaning, decontamination and sterilization of patient rooms and isolation rooms. Hospital Housekeeping Aids are responsible for the removal of refuse from the hospital and are exposed to bodily fluids Including loose blood and sharps improperly disposed of in the general refuse of the hospital where by exposing them to needlesticks and being contaminated by bloodborne pathogens. Hospital Housekeeping Aids are responsible for the removal of Biohazardous Waste from the various floors of hospitals further exposing them to the likelihood of exposure to bloodborne pathogens and the inherent risks associated with these assigned duties. There are 4 levels of housekeeping and they include General Housekeeping, Industrial Housekeeping, Institutional Housekeeping and Hospital Housekeeping. As a matter of fact, the Office of Personnel Management (www.opm.gov) has recognized the unique and differentiated requirements and duties associated with housekeeping in a hospital environment and created the titles Hospital Housekeeping Officer and Hospital Housekeeping Assistant due to extraordinary measures necessary to maintain a healthy environment for patients, visitors and staff of hospitals. Although housekeepers are looked on by many as minimally educated “Janitors” (which by the way is not an accurate assessment), these employees play a unique and vital role in maintaining a hospital’s environment through the mitigation and abatement of bacteria and disease through their job functions. A thorough review of this regulation and specific inclusion of hospital housekeeping staff is long overdue and in order. These vital “healthcare workers” play an integral part in maintaining compliance through The Joint Commission.