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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.

Feedback Form

All Feedback

  1. 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
  2. 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
  3. 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
  4. 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
  5. 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
  6. 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
  7. 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
  8. 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