Inspection Findings:
Based on observation, interview and record review, it was determined the facility failed to follow Centers for Disease Control and Prevention (CDC) guidelines for disposing, cleaning and storing of personal protective equipment (PPE) for 1 of 1 sampled resident (#184) reviewed for infection control related to COVID-19 and failed to follow manufacture's guidance related to use of disinfection products for infection control precautions in relation to COVID-19 prevention. This placed residents and staff at risk for infection and illness related to the COVID-19 virus. Findings include:
1. According to the CDC Strategies for Optimizing the Supply of Isolation Gown, updated 1/21/21:
Once personal protective equipment (PPE) supplies and availability return to normal, healthcare facilities should promptly resume conventional practices.
Re-use of isolation gowns. The risks to healthcare provider (HCP) and patient safety must be carefully considered before implementing a gown reuse strategy. Disposable gowns generally should NOT be re-used, because reuse poses risks for possible transmission among HCP and patients that likely outweigh any potential benefits.
According to CDC's Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19 Pandemic):
Any reusable PPE must be properly cleaned, decontaminated, and maintained after and between uses.
According to Oregon Health Authority guidance:
If eye protection is being reused, establish a dedicated area in the facility to clean, disinfect, and store eye protection between uses (preferably near facility entrance/exit). Disinfection should occur immediately after removing eye protection. Social distancing should be observed at and around the disinfection station. Personal protective equipment should not be shared between staff.
After cleaning/disinfection/drying, eye protection can be stored in a transparent plastic bag or container, and labeled with the staff member name to prevent accidental sharing between staff.
Resident 184 was admitted to the facility in 5/2021 and placed on 14-day droplet precautions that required all staff and visitors wear full PPE. The resident was in a private room.
On 5/14/21 at 3:03 PM, the door to Resident 184's room was open. Directly inside the doorway of the room were five hooks placed on the wall, three on the left side behind the opened door and two on the right side. Each of the five hooks had a blue disposable isolation gown hanging on it. Four face shields, three on the left side and one on the right side, were also hanging on the same hooks with the inside of each face shield directly facing the hanging isolation gowns.
A PPE cart was located right outside of Resident 184's room. The cart contained new PPE supplies (gloves, blue disposable isolation gowns, masks, and two different containers of disinfecting wipes) and plastic bags.
On 5/14/21 at 3:46 PM, Staff 5 (CNA) entered Resident 184's room after donning full PPE (mask, disposable isolation gown, gloves and face shield) to provide care. After providing care, Staff 5 noticed the five hanging isolation gowns and disposed of four of them in a covered trash receptacle in the resident's room, leaving one isolation gown still hanging. Staff 5 left the four face shields hanging on their hooks. Staff 5 then hung up her face shield on one of the hooks without disinfecting or storing it in a plastic bag. Staff 5 exited the room after doffing the rest of her PPE.
When asked about the use, storage and disposal of PPE, Staff 5 stated she used the disposable isolation gown once and disposed of it immediately afterwards. She stated this process had recently changed as staff had previously used the same gown for their entire shift. Staff 5 then stated the hanging isolation gowns she disposed of belonged to other staff who had cared for the resident earlier in the day. In regards to her face shield, Staff 5 stated she received a new face shield each shift. Since Resident 184 was the only resident on droplet precautions, Staff 5 used the same face shield throughout her entire shift and stored the face shield in the resident's room. Staff 5 stated she did not disinfect her face shield between uses in the resident's room or store the face shield in a storage bag afterwards.
In an interview on 5/13/21 at 12:30 PM, Staff 1 (Administrator) stated the facility had a three months supply of PPE, including disposable isolation gowns. She stated there should not be any reuse of PPE.
In an interview on 5/14/21 at 4:41 PM, Staff 3 (Assistant DNS and Infection Preventionist) stated staff should not be reusing disposable isolation gowns and should be disinfecting face shields between use and appropriately storing them. Staff 3 acknowledged this was not done.
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2. Centers for Disease Control "Interim Infection Prevention and Control Recommendations for Healthcare Personnel During Coronavirus Disease 2019 (COVID-19) Pandemic" revised 7/15/20 instructed facilities to ensure environmental cleaning and disinfection procedures were followed consistently and correctly.
The disinfecting solution (Signet Neutral Disinfectant) used within the facility had manufacturer's instructions which stated "treated surfaces must remain wet for 10 minutes ... allow to air dry."
On 5/10/21 at 10:36 AM, Staff 8 (Housekeeping) was interviewed about disinfection of surfaces in residents' rooms and communal areas. Staff 8 stated that Signet Neutral Disinfectant was sprayed on surfaces, left on for five seconds, then wiped away.
On 5/12/21 at 10:35 AM, Staff 9 (Housekeeping) was observed using Signet Neutral Disinfectant on surfaces in an isolation precaution room. Staff 9 sprayed the disinfecting product on surfaces and wiped those surfaces dry immediately. Staff 9 was interviewed about use of Signet Neutral Disinfectant. Staff 9 stated they sprayed the product on a surface, waited 30 seconds, and then wiped it off.
On 5/12/21 at 1:48 PM, Staff 7 (Housekeeping Supervisor) was interviewed about disinfection products used in the facility. Staff 7 stated the contact time for Signet Neutral Disinfectant was 30 seconds. The concentrate dispenser label was reviewed regarding contact time for the disinfectant with Staff 7 to which she corrected her previous statement, stating that 10 minutes was the correct contact time for that product.
On 5/14/21 at 4:05 PM, Staff 1 (Administrator) stated an understanding of the need for a 10 minute contact time with Signet Neutral Disinfectant in order to disinfect surfaces.
Plan of Correction:
-Current Resident
-Resident 184 no longer in facility
-Potential residents
-No longer re using PPE for residents on precautions
-All residents at potential risk with contact of disinfected surfaces
-Systemic changes to ensure deficient practice does not reoccur
-LNs will be in serviced on surface cleaning and PPE protocol at the LN meeting on 6/9/21, CNAs will be in serviced on surface cleaning and PPE protocol at the CNA meeting on 6/16/21, housekeeping staff will be in serviced on surface cleaning and PPE protocol on 6/29/21.
-All disinfecting bottles and packaging will be labeled with contact times
-Sustainability/Monitoring:
-PPE protocol and surface cleaning audit will be completed by ADON for 5 staff members per month to ensure compliance
-ADON will report audit results to monthly QAPI committee to ensure POC is achieved and sustained. Continued frequency of audits will be determined by QAPI committee
-Monthly QAPI meeting to review any incidents and training compliance issues