Comment from Tichenor, Gregory; Gregory A. Tichenor, MD

Document ID: OSHA-2010-0003-0005
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: May 13 2010, at 09:06 AM Eastern Daylight Time
Date Posted: May 13 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 6 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: August 4 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80aeca33
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This is comment on Notice

Infectious Diseases

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In theory, regulations trying to protect physicians, nurses and other health care workers are a good idea, I fear that they will simply add to our already overwhelming regulatory burden. As an emergency physician I can assure you we already have plenty of incentive to protect ourselves. We have hospital infection control people and corporate spys to make sure we wash or gell our hands. We have the Joint Commission making sure we don't eat or drink anywhere near patient care areas. Of course no one seems to be able to explain why it is OK for patients and families to eat and drink in their rooms but we can't have a cup of coffee at our desk. Lastly, we have our own sense of self-preservation and altruism to protect us and the patients. I fear all we will see is rules forcing front-line workers to do more busy work while allowing management (where I spend half my time) to escape responsibility. If you want to help you should concentrate on encouraging facilities to explore enviornmental, technological and facility design solutions to infection control. Otherwise we will just get more of the same.

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