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Closed Public Consultation: Blood Borne Pathogens

About this consultation

As part of the College’s commitment to risk-based regulation, we have developed a rigorous approach to policy making to ensure policy decisions are based on a proper evaluation of risk, solid evidence, and a thorough analysis of options and impacts. This process ensures that regulatory tools are not adopted as the default solution, but are introduced to mitigate risk when other non-regulatory options are unable to deliver the desired results.

Consultation with midwives, midwifery and regulatory organizations, and the public is an essential part of our policy development process, and in keeping with our guiding principles of accountability and transparency.

Background

The transmission of a blood borne pathogen (or virus) from a midwife to a client is exceedingly low, but the possible outcome is serious. Midwives who have high viral loads of HIV, Hepatitis B, or Hepatitis C may infect their clients during an exposure-prone procedure such as perineal repair. The diseases that result from an infection with these viruses can be managed, but cannot be cured.

To help mitigate this risk, the Public Health Agency of Canada (PHAC) recommends that Colleges provide guidance to their membership about preventing the possible transmission of a blood borne virus from a health care worker to a client. 

The College has a Blood Borne Pathogens standard that was implemented in 2003 and last revised in January 2014.

Our proposal

We are requesting feedback from midwives, the public and stakeholders about our proposal to revise the standard Blood Borne Pathogens to:

  • Set minimum expectations for midwives to test for and manage their health when infected with a blood borne pathogen which includes being in the care of a physician expert.
  • Fulfill the requirements of PHAC guidance recommending the regulator has a role in setting standards about blood borne pathogens in their membership.

Revision to the standard will involve the following:

  1. Change the name of the standard from Blood Borne Pathogens to Blood Borne Viruses to reflect the current language.
  2. Change the requirement for periodic testing for blood borne viruses to testing every three years for Hepatitis C and HIV, and every year for Hepatitis B if no evidence of immunity exists. This clearly sets out the requirement for testing frequency based on the transmissibility of each of the viruses and does not leave it up to the individual midwife what “periodic” testing means.
  3. Replace the requirement for midwives to report to the College when they are seropositive for a blood borne virus with the requirement that midwives must report at annual renewal that they are complying with this standard. This will serve as an annual reminder to review the standard to ensure compliance with it.

Please review:

  • Our current Blood Borne Pathogens standard
  • Our proposed Blood Borne Viruses standard
  • Consider: Are the proposed requirements clear? Is the standard achievable for all midwives? Is there anything missing?

How to provide feedback

You may submit your comments using this page.

All comments are reviewed before being posted publicly to ensure they meet the Posting Guidelines. Your name and email will not be published with your feedback, however, you will be identified as a member of the public, a midwife, or a stakeholder. Email addresses are required to ensure that each individual only provides feedback once. If you prefer to provide feedback via email, want to respond using a different format, or if you have any questions about the consultation, please email us at cmo@cmo.on.ca.

This consultation will be open until Friday, November 12, 2021.

All Feedback

  1. Midwife

    I do not agree with the proposed new standard. It needs significant changes. Thank-you!

    • Are you a: Midwife
    • On behalf of: Yourself
  2. Midwife

    I disagree with the proposed changes. I would want to know what evidence the College is using to support q3yearly testing as a means of reducing midwife to client transmission of blood borne viruses. The cited Public Health guideline does not include this recommendation as far as I can tell. Midwives are already accountable to their privileging hospitals’ Occupational Health requirements which should be adequate.

    • Are you a: Midwife
    • On behalf of: Yourself
  3. Midwife

    I STRONGLY OPPOSE this proposal. Like many have already stated, I do not believe this is the standard for physicians and nurses with comparable transmission risk as midwives do. As such, this should not be expected of midwives. But beyond that, at the very core of this issue is that personal health information should not be linked with my ability to practice.

    • Are you a: Midwife
    • On behalf of: Yourself
  4. Midwife

    seems reasonable

    • Are you a: Midwife
    • Organization: east ottawa midwives
    • On behalf of: Yourself
  5. Midwife

    This testing is not available at our hospital, as they do not test health care workers on a schedule for these infections. My feedback is if this not a standard of care for any health care workers at our hospital, why are midwives unique and subject to repetitive screening that may involve cost and inconvenience? Is there new research or evidence to support this practice in fact decreasing risk to clients?

    • Are you a: Midwife
    • On behalf of: Organization
  6. Midwife

    I’m strongly opposed to this proposed change.
    Universal precautions is/has been working to make sure there is no risks to ourselves or the public. I’d like to know where this proposition is coming from? What data is triggering the need for change? Has there been increases in client-RM or RM-client transmission over X period of time?
    Testing q3y wouldn’t really change the fact that we would need to test following a needle stick injury anyway. I don’t see the importance for changing this requirement. The way it was worded before is sufficient.

    • Are you a: Midwife
    • On behalf of: Yourself
  7. Midwife

    I strongly disagree with this proposed change in our standard of care. Midwives are experts on Universal Precautions and in using PPE. It is a costly and invasive procedure and midwives should not have to be subject to this type of testing on such s regular basis to maintain our designation. Are OB’s, nurses, paediatricians, etc expected to do the same? Has there been a drastic increase in transmission from midwives to client to warrant considering such a change? This seems like a slippery slope to me. What’s next?

    • Are you a: Midwife
    • On behalf of: Yourself
  8. Midwife

    This is follow up to my previous comments. I have had a meeting with the occupational health dept within my hospital who have confirmed that the OMA/OHA requirements are to demonstrate immunity to HepB one time (upon privileging) and HIV/HepC testing only done if exposed, ie, a punctured glove. I also inquired as to whether this testing could be completed simply to fulfill CMO policy and the answer was no due to additional declaration forms required for the HIV component of testing. Thus midwives would be directed to their GP. Questions: why are midwives being held to a different standard than other health care providers? would there be barriers to accessing testing, ie, midwife doesn’t have a GP? Would their be a cost to testing given that it’s for work?

    • Are you a: Midwife
    • On behalf of: Yourself
  9. Midwife

    I’m curious to know whether testing every 3 years for HIV and HCV is in line with other regulated professionals with a similar risk exposure, ie, physicians. Testing is not required by occupational health at the hospital level unless there is an exposure such as a puncture wound while providing care. Thus will midwives be able to access this testing via occupational health at a hospital level if it’s not required by the institution? If not, is it accessible through the health care system if it’s work related only?
    Also if immunity to HBV has been established what is “periodic” checking of immune status? Does the literature recommend checking every 3, 5, or 10 years? This is unclear.

    • Are you a: Midwife
    • Organization: Burlington & Area Midwives
    • On behalf of: Yourself
  10. Midwife

    I do not agree with this proposed change of standard. This should not be linked with a midwife’s registration status.

    • Are you a: Midwife
    • On behalf of: Yourself
  11. Midwife

    I do a NOT agree with this change in standards in order to uphold our college registration as it does not do anything to prevent infection/transmission in the general public/midwife client relationships. We are held to a standard in regards to regular use of PPE and universal precautions in the workplace. Mandatory testing/medical procedures to uphold our professional status within the college removes our access/freedoms as HCP to make an informed choice free of coercion in order to maintain our licenses and make a living.

    • Are you a: Midwife
    • On behalf of: Yourself
  12. Midwife

    I think the proposed alterations to the current Standard needs to be considered in light of the following: has there been a steady incline in midwife-to-client blood-born pathogen transmission? Has there been an incline in midwife-to-client transmission of blood-born pathogens in circumstances that appropriate precautions are being taken? This way, both clients, their families, and midwives can better evaluate whether changing the already existing Standard is likely to produce measurable benefits.

    • Are you a: Midwife
    • On behalf of: Yourself
  13. Midwife

    I do not agree with this change of policy. A midwife registration should not be linked to personal health information.

    • Are you a: Midwife
    • On behalf of: Yourself
  14. Midwife

    Provided all we need to do is confirm we are following this standard, I am ok with it from the perspective of protecting the public-especially with Hep C infection being possibly asymptomatic. I am curious to know where the recommendation to test q3 years comes from-seems quite frequent. May help to state within the guideline exactly where this recommendation comes from even if sited.

    • Are you a: Midwife
    • Organization: Born Midwives
    • On behalf of: Yourself
  15. Midwife

    I disagree with this standard as proposed – it is unnecessary, costly, invasive, and time-consuming to have annual testing. Midwives should get tested only if they are exposed to HIV/Hep C.

    • Are you a: Midwife
    • On behalf of: Yourself
  16. Midwife

    I do not agree with this change in standard as proposed.

    • Are you a: Midwife
    • On behalf of: Yourself
  17. Midwife

    I think the new guideline is an improvement. It is succinct, accurate, and reasonable on all accounts.

    • Are you a: Midwife
    • Organization: Community Midwives of Ottawa
    • On behalf of: Yourself
  18. Midwife

    I strongly disagree with testing and reporting requirements purely for maintaining registration, whether in regards to CPSO policy or proposed changes to the CMO policy. It is ableist and stigmatizing, does not do anything to “protect the public” (isn’t this why we use universal precautions??), and frankly clinically ridiculous. I disagree that simply performing within our midwifery scope puts us at a higher than normal risk for potential HIV or HCV infection…should we also then be suggesting that any midwife participating in intercourse without a condom test q3-6 months?

    • Are you a: Midwife
    • On behalf of: Yourself
  19. Midwife

    The annual testing requirement is unnecessary unless exposure has occurred, is invasive and should not be required to remain registered.

    • Are you a: Midwife
    • Organization: n/a
    • On behalf of: Yourself
  20. Midwife

    If I understand the standard correctly, as a midwife who has been practicing for 16 years, I should have been testing for HIV and Hep C every 3 years? I have no reason to suspect I have either, but according to the standard because I repaire péri runs, I need to be tested regularly? This is how I understand the standard.

    • Are you a: Midwife
    • Organization: CMOB
    • On behalf of: Yourself
  21. Member of the public

    It seems that this policy is in like with the CPSO policy for testing, specifically because of the higher risk of “exposure-prone procedures” with midwives and physicians. The standard is not saying that midwives need to disclose their status at yearly renewal, just that they are complying with the standard (complying with recommendations and undergoing testing as required), which seems reasonable. Although I understand folks not wanting to be required to do this, it is for the public’s protection.

    • Are you a: Member of the public
    • On behalf of: Yourself
  22. Midwife

    For a midwife with previously proven immunity, there is no need for yearly testing. The only reason to be tested is after an exposure risk. For midwives without proven immunity, but with past proof of no current infection, there is also no reason for testing unless there has been an exposure. A midwife’s ability to remain licensed should not depend on her private health information. Routine testing of a person without any exposure incidients should be a decision made between the person and their physician, not the person and the CMO. Testing without clinical indication (ie exposure to infection) is a waste if resources, time, and a violation of a person’s right to make their own health care decisions with their own primary care provider. Routine prenatal screening already includes screening for blood borne viruses which we offer to all clients, so we will always be able to identify where is risk for the midwife. And midwives who have had hospital privileges have likely needed to submit blood borne virus screen (also likely would have needed to be done during midwife education). Without any exposure to these viruses in the time between when the test was done and the current time, there is no reason to suspect infection and no reason to do indefinite repeat testing.

    • Are you a: Midwife
    • On behalf of: Yourself
  23. Midwife

    I am not aware of any other health professionals requiring this level of testing for HIV and HepC. I did require proof of hep B vaccination at one time but no other proof of this has been required. I do not think this standard is in line with Public Health measure of other health care workers or with other similar Colleges.

    • Are you a: Midwife
    • Organization: Blue Heron Midwives
    • On behalf of: Yourself
  24. Midwife

    If I have understood this correctly, this proposal is asking all midwives undergo an invasive procedure (venipuncture) every three years whether or not they have had an exposure risk?

    • Are you a: Midwife
    • On behalf of: Yourself
  25. Midwife

    This standard is over reaching. Other professional colleges in Ontario do not require the disclosure of this information nor do they require mandatory testing.

    As well, the standard needs to clarify what would be considered an acceptable test. Ie. Would donating blood count since the testing is done but the donor doesn’t have access to the test results directly bit would be notified if they were positive.

    • Are you a: Midwife
    • On behalf of: Yourself

Comments are closed.