Managing health and safety risks of respiratory infection transmission in medical practice

Risk management for workplace health and safety (WHS) risks includes identifying the hazards, conducting a risk assessment, consulting with staff, determining measures to minimise or eliminate the risks and implementing those measures.

The COVID pandemic saw practices implementing novel measures to manage the risk of respiratory illness transmission including face coverings, vaccinations, taking sick leave when infected, respiratory etiquette, hand sanitising and COVID testing. Many of these measures continue to be used to mitigate the risks of transmission of a range of respiratory illnesses. 

A critical tool in managing these risks is properly performed risk assessment.  This will help you comply with your WHS requirements and manage other risks, such as the risk of a discrimination claim.

A risk assessment allows you to identify:

• The risks associated with the transmission of a respiratory infection.
• The measures that could be implemented to minimise or eliminate the risks.
• The measures that should be implemented to minimise or eliminate the risks.

Risk assessment is an ongoing process.

Yes, it should be in writing.

Documenting the risk assessment will assist with your preparation and communication with your workers.

It may also be required in response to a request from a work health and safety inspector.

Safe Work Australia has information and a template example for managing COVID risk that can help businesses understand how to identify and mitigate risks of respiratory illness.

General information | Safe Work Australia

 Example risk register | Safe Work Australia

Safe Work Australia has provided the following guidance:

Identify, assess and control hazards - Managing risks | Safe Work Australia

Assessing and managing risks  | Safe Work Australia

How to manage work health and safety risks | Safe Work Australia

Safe Work Australia has provided the following guidance:

Key considerations for undertaking a risk assessment | Safe Work Australia

Examples of the matters to consider include:

• advice from state and federal health departments
• advice from work health and safety bodies such as Safe Work Australia
• advice from your college or other professional body
• the rate of community transmission
• the risk of transmission in your practice, having regard to the nature of the work performed, and patients seen, in your practice
• the nature of the services your practice provides
• the consequences of your practice refusing access to the medical service
• the characteristics of people who attend your practice and whether there is a heightened risk they will suffer severe disease (for example, people over 60 or people with pre-existing health conditions)
• the time people generally stay inside the medical practice when receiving medical services
• whether it is possible to socially distance in the practice
• availability of measures to manage risk such as personal protective equipment (PPE) and face coverings
• whether workers interact with a large number of people such that a “super-spreading” event could arise
• the other control measures that your practice has in place
• where the practice is located (for example, in private hospital grounds)
• how workers travel to work.

Risk to your practice will be determined by all the above considerations. Examples could be:

• respiratory infection transmission worker to patient/visitor
• respiratory infection transmission worker to worker
• respiratory infection transmission patient to patient
• respiratory infection transmission patient to worker
• adverse effect from wearing PPE
• adverse effect from sanitiser and cleaning substances
• worker shortages for isolation or illness
• worker serious illness
• aggressive patients
• delayed or missed diagnosis
• staff complaints and disputes
• staff resignations
• workers travelling to work on public transport
• working from home
• fatigued workers
• working in more than one clinic
• managing pop up clinics
• sharing equipment
• mental health issues of staff and patients
• patient privacy.

Consultation | Safe Work Australia

Some practical steps are listed below.

• Have a practice meeting to discuss the risk assessment and what it means for staff.
• Invite the team to review the risk assessment and give input about their concerns and possible alternatives before implementation of the measures.
• Invite the team to speak to you about their concerns and individual circumstances.

Make sure you document the consultation process (for example, minutes of meeting, email to staff).

We recommend that practices update their workplace safety plan as they decide on new measures to manage the risks associated with respiratory infection transmission.

RACGP – COVID Safe Plan template

RACGP – Managing pandemic influenza in general practice

Examples include:

• identification of patients with possible respiratory infections before they enter the premises
• physical distancing
• good hygiene
• increased cleaning, with an emphasis on high touch points such as doorknobs and pens
• additional training
• personal protective equipment
• perspex screens
• removing items such as toys and magazines from waiting rooms
• telehealth and video consultations
• seeing patients in the car park or another area outside the practice
• mandatory face masks for workers and patients
• mandatory vaccination for workers and patients
• working from home when unwell
• educate patients about health and safety measures
• possible alternative measures for staff and patients who cannot comply due to disability
• patients with symptoms entering via a back entrance or being placed in an isolation room
• disposable or single use pens and pencils
• a designated isolation area for suspected infected patients.

How to Determine what is Reasonably Practicable to meet a Health and Safety Duty | Safe Work Australia

This is a decision for you and your team based on the risks and control measures you have identified.

When performing the risk assessment, you should consider whether there are alternate measures that the practice could implement so a patient's care is not compromised. Examples include:

• patients entering via a back entrance
• an isolation room for patients who cannot comply with measures
• consulting with patients in the car park
• setting consultation times at the end of the day for a high-risk patient so the practice can prepare and clean
• consulting with the patient in full PPE (including N95 or P2 masks)
• offering telehealth consultations if appropriate
• offering options other than attending the practice (for example, attending the local hospital).

When performing the risk assessment, you should:

• consult with your team to design mitigation strategies
• offer a confidential forum for the worker to discuss concerns with management
• consider whether there are alternate measures that the practice could implement if a worker cannot or will not comply with a measure.

You should have regard to any medical reports the worker provides. Examples include:

• alternate duties
• working from home
• wearing full PPE at work (including N95 or P2 masks)
• taking leave
• telehealth appointments.

A risk assessment can be used to address many different potential risks a practice may experience. In this instance, following the lessons learnt from the COVID pandemic, a respiratory illness assessment is an important part of any practice’s risk management process.

For medico-legal advice, please contact us on nca@avant.org.au or call 1800 128 268, 24/7 in emergencies.