AHPRA Guidelines for the regulation of health practitioners and

5 September 2014 Dr Joanna Flynn AM Chair Medical Board of Australia Australian Health Practitioner Regulation Agency G.P.O. Box 9958 Melbourne VIC 3001 Email: c/‐ [email protected] Dear Dr Flynn Australian and New Zealand College of Anaesthetists Response to proposed guidelines for the regulatory management of registered health practitioners and students infected with blood‐borne viruses The Australian and New Zealand College of Anaesthetists (ANZCA), which includes the Faculty of Pain Medicine, is committed to high standards of clinical practice in the fields of anaesthesia and pain medicine. ANZCA is the education and training body responsible for the postgraduate medical training programs and continuing professional development in anaesthesia and pain medicine for Australia, New Zealand and parts of Asia. As requested please find responses to the questions below: 1. Is a guideline necessary? Yes. A guideline is necessary as it is important for the Boards to provide advice to registered health practitioners and students infected with blood‐borne viruses, on their scope of practice. 2. Is the content of the guideline helpful, clear and relevant? Yes. The guidelines provide a useful framework for considering this issue from different perspectives. The document is clear and easy to read due to the separation of issues under the following key headings:  Guidance for all registered health practitioners and students  Registered health practitioners and students with blood‐borne viruses  The Board’s response to a registered health practitioner or student with a blood‐borne virus  Treating doctors 3. Is there any content that needs to be changed, added or deleted in the guideline? No. 4.
Do you agree with the proposal that Boards expect registered health practitioners to comply with CDNA guidelines for the management of health practitioners infected with a blood‐borne virus? That includes following advice on their scope of practice based on the CDNA guidelines. This would seem reasonable. It would be important for the Board to keep abreast of any changes to the CDNA guidelines and then inform registered health practitioners and students when something has materially changed within the document. 5.
Do you believe that there is any conflict between these guidelines and any other guidelines for the management of practitioners infected with a blood‐borne virus? Is there any conflict with any obligations that may arise in the workplace? No. 6.
Is it reasonable and appropriate for the Board to take regulatory action only if a practitioner who is infected with a blood‐borne virus is placing the public at risk? Yes. This would seem a pragmatic stance considering the risk of transmission by HCW to the public is extremely low. Similarly the likelihood of a HCW refusing to comply with CDNA Guidelines is also very low. A more intrusive regulatory approach would seem unjustified from a risk or cost perspective. 7.
Do you have any other comments on the guideline? The guideline provides an accessible pathway to existing knowledge for both clinicians and AHPRA. It recognises the respective roles of a regulatory body (AHPRA) and an expert group providing scientific evidence (CDNA). It clearly defines notification requirements and exposure prone procedures making it a readily accessible document. Thank you for the opportunity to comment. Should you require any further information, please contact Jonathon Kruger, General Manager Policy via email [email protected] or telephone +61 3 8517 5341. We look forward to the outcomes of the current consultation. Yours sincerely Dr Genevieve Goulding President

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