Fact sheet: Exposure-prone procedures - registration and renewal declaration

In July 2020, the Guidelines: Registered health practitioners and students in relation to blood-borne viruses took effect (NMBA guidelines). The NMBA guidelines inform nurses, midwives and students that they must comply with the Communicable Diseases Network Australia (CDNA) guidelines Australian national guidelines for the management of healthcare workers living with blood borne viruses and healthcare workers who perform exposure prone procedures at risk of exposure to blood borne viruses 2018 (CDNA guidelines). The CDNA guidelines apply to all registered health practitioners.

To ensure nurses and midwives comply with the CDNA guidelines, from the 2021 renewal period onwards new questions have been added to the renewal process. Similar questions have also been added to the registration application process.

The following questions and answers provide detail to common queries on the CDNA guidelines and what it will mean for you on application for registration and at registration renewal.

The CDNA guidelines provide guidance on testing for blood borne viruses (BBV) and the circumstances when health practitioners living with a BBV can resume performing exposure prone procedures (EPPs). This is based on current evidence and international practice and applies to all registered health practitioners.

The CDNA guidelines are for:

• health practitioners who perform EPPs
• health practitioners living with a BBV
• health practitioners who treat healthcare workers with a BBV, and
• public health authorities.

The CDNA guidelines and other helpful resources are available on the Department of Health website and includes information sheets for health practitioners living with a BBV who perform EPPs and for those who perform EPPs and are not living with a BBV.

The NMBA will be asking nurses and midwives when applying for registration and at registration renewal whether they perform EPPs in their practice and additional questions about compliance with the CDNA guidelines.

It is important that you have a clear understanding of the CDNA guidelines before completing your declaration. The application and renewal forms will include relevant definitions, information and links to resources to help you answer accurately.

EPPs are procedures where there is a risk of injury to the health practitioner resulting in exposure of the patient’s open tissues to the blood of the health practitioner. These procedures include those where the health practitioner’s hand (whether gloved or not) may be in contact with sharp instruments, needle tips or sharp tissues (spicules of bone or teeth) inside a patient’s open body cavity, wound or confined anatomical space where the hands or fingertips may not be completely visible at all times.

Non-exposure prone procedures are where the hands and fingers of the health practitioner are visible and outside of the body at all times, and procedures or internal examinations that do not involve possible injury to the healthcare worker’s hands by sharp instruments and/or tissue – provided routine infection prevention and control procedures are adhered to at all times. Examples of non-EPPs are performing a vaginal examination that does not include using a sharp, clamping the neonatal umbilical cord during a water birth (where the hands are visible at all times) or the routine insertion of an indwelling catheter.

The majority of nurses do not perform EPPs. Midwives who work in birth suites or homebirth settings may perform EPPs. Midwives that do not practice in these areas are unlikely to perform EPPs.

Examples of EPPs include a midwife repairing an episiotomy, assisting with a caesarean birth, applying a fetal scalp electrode or a perioperative nurse or nurse surgical assistant involved in open surgical procedures. The CDNA guidelines provide further information in its publication Guidance on classification of exposure prone and non-exposure prone procedures in Australia (2017).

When you apply for registration, you will be asked if you will be performing EPPs in your practice. You may not know if you will be performing EPPs in your practice, particularly if at the time of lodging your application you may not know where you will be practising.

If you do not know if you will be performing EPPs in your practice, you can answer ‘no’ to this question and you will proceed to the next question. If you know you will be performing EPPs (see the examples above), then you must answer ‘yes’ to this question.

If you intend to perform exposure prone procedures (EPPs) in the upcoming registration period, you must declare this at registration renewal and comply with the CDNA guidelines. This includes testing for HIV, Hepatitis C and Hepatitis B (HBV) at least once every three years. Testing for HBV is not necessary if you have demonstrated immunity to this virus through vaccination or resolved infection.

When you answer ‘yes’, you will be asked a second question that states ‘if your registration is renewed, do you commit to comply with the CDNA guidelines?’ You will not be able to proceed with the renewal application until you answer ‘yes’ to this question.

In the 2022 registration renewal period if you responded ‘Yes’ to both of the above questions, you will be asked if you complied with the CDNA guidelines during the previous registration period.

At registration renewal you will be asked to declare if you perform EPPs in your practice. If you do not perform EPPs you simply answer ‘No’.

If your role changes in the upcoming registration year and in that role you do perform EPPs you should answer ‘Yes- I do perform EPPs at your next renewal and then you will be asked if you have complied with the CDNA guidelines.

Compliance with the CDNA guidelines includes testing for HIV, Hepatitis C and Hepatitis B (HBV) at least once every three years. Testing for HBV is not necessary if you have demonstrated immunity to this virus through vaccination or resolved infection.

The CDNA guidelines do not prescribe additional responsibilities of employers, as it is the individual practitioners’ responsibility to comply with the guidelines. It is also important to note that most nurses and midwives do not perform EPPs. See the section above ‘What are examples of EPP for nurses and midwives? ’.

The CDNA provides an information sheet for employers of healthcare workers who perform EPPs (see ‘For more information’). The information sheet supports employers to understand how to apply the guidelines in line with relevant public health, antidiscrimination, privacy, industrial and equal employment opportunity legislation that is specific to your jurisdiction.

The information sheet includes content on whether an employer can ask for evidence of BBV status or initial clearance and what to do if a patient is potentially exposed to a BBV.

The Communicable Diseases Network Australia (CDNA) has also purchased the following information sheets:

• Guidance on classification of exposure and non-exposure prone procedures in Australia (2017).
• Healthcare workers living with a blood borne virus who perform exposure prone procedures
• Employers of healthcare workers who perform exposure prone procedures

You can also seek information from your relevant professional association/specialist college, on which procedures in their specialty constitutes an EPP.