PHW: IPC guidance
Public Health Wales (PHW) have published a document: Infection Prevention and Control (IPC) Guidance for Special Procedure in Wales – Version 1. Unfortunately, we believe that the advice on swabbing and location of sharps boxes does not represent best practice. The information below will equip you to discuss these issues with your environmental health officer. Thereby, minimising the chances that the guidance will adversely affect your practice.
We have written to PHW to raise our concerns. Discussions are ongoing and we hope that the guidance will be amended. In the short term, PHW have stated that the document is for guidance and your environmental health officer ‘needs to be assured of mitigation for infection so you just need to be able to demonstrate this to them’. In other words, ultimately it will be the environmental health officer’s decision.
Below you can find information relating to:
- disposal of couch roll
- swabbing prior to needling
- location of sharps boxes
- if you missed the deadline
- faster exam results having been negotiated
- Wales community webinar
Disposal of couch roll
We have had reports of licensing officers stating that couch roll needs to be disposed of in special waste.
- If couch roll is uncontaminated by body fluids, this is incorrect according to public health wales guidelines.
- If it is contaminated with body fluids it is ‘offensive but non hazardous’ so needs a tiger bag.
The evidence is in this PHW document:
In appendix 4, it specifically states that unmarked couch roll should be treated as household waste. Earlier in the document, it also explicitly states that this kind of waste *should not* be placed in the offensive or clinical waste stream.
Swabbing prior to needling
In section 1. Health risks associated with special procedures: Key messages it states:
Adequate skin cleansing with the use of antiseptics prior to the procedure being undertaken. Ensuring the skin is visually clean.
In section 5. Skin preparation and antisepsis prior to the special procedure
Apply a large alcohol-based single swab sachet of 70% isopropyl alcohol to chemically disinfect the skin area…
The citation given to support this recommendation is NICE [NG125] Surgical site infections: prevention and treatment. However, this is not the most appropriate guidance to follow for acupuncture. Acupuncture is more akin to injections for vaccinations. In the ‘WHO best practices for injections and related procedures toolkit’ (2.1.4) alcohol swabs should not be used for vaccinations. The NHS Green Book Chapter 4: Immunisation procedures states:
If the skin is clean, no further cleaning is necessary. Only visibly dirty skin needs to be washed with soap and water.
Recent research also demonstrates that swabbing does not reduce infection but does increase pain [1, 2]. Each acupuncture session will normally involve multiple needle insertions, typically between 8-10. To avoid cross-infection the swabs must be single use. Potentially, there could be unintended negative consequences arising from this requirement: there will be an environmental cost to the use of so many swabs and sachets; greater discomfort for the patient; a small financial cost. Potentially, the opening of so many sachets may lead to a higher risk of infection.
Therefore, we have recommended to PHW acupuncture specific guidance should be included in the document, noting the BAcC guidance is:
Swabbing is only indicated for patients who have a suppressed immune system through illness or medication and is not required in the fit and healthy.
Sharps boxes
10.4 Sharps waste:
Sharps bins should not be stored on the floor to prevent them being accidentally kicked over spilling sharps onto the floor. They should be out of reach by members of the public. (p43)
The requirements that the sharps box is out of reach by members of the public is potentially confusing. Naturally, acupuncturist will be working in very close proximity to patients, and they will also need to dispose of the needles easily. We are concerned that this may not be practical. Potentially, practitioners may decide to place the sharps box at a distance from the treatment couch. This will increase the distance travelled while carrying used needles. The WHO recommend sharps boxes should be within arm’s reach (1.5).
References
- Lafleur, B., et al., Omission of alcohol skin cleansing and risk of adverse events in long-term care residents undergoing COVID-19 vaccination: A cohort study. Human Vaccines & Immunotherapeutics, 2024. 20(1): p. 2368681.
- Dulong, C., K. Brett, and C. Argáez, Skin Preparation for Injections: A Review of Clinical Effectiveness, Cost-Effectiveness and Guidelines. 2020.
License application deadline was end of February
The deadline to get our licensing applications in was the end of February. You can still apply but the stated deadline to have your transitional license extended is to get your application was by the end of February. If you missed the deadline, then the stated situation is that you will then be unlicensed (see below about this). If you got your application in before, then then your transitional license will continue until you have had your application processed so it ensures you stay licensed.
In order to put your application in, you must have everything in place to do this. You can see a full list of what you need here: https://acupuncture.org.uk/wales-licensing-adaption-checklist/
Please don’t delay. IF YOU HAVEN’T got your Level 2 Infection Control qualification, then this is the thing to address most urgently.
What to do if you are short of time
If you are worried about time and have missed the deadline at the end of February, contact your local council licensing office and explain the situation. They may be amenable to your situation. Communicating is definitely the best option. Many council officers know that BAcC Members are already working to the highest standards, so if you show that you are serious about standards and licensing and are in the process of applying, we feel that this will give you the best chance of receiving some flexibility.
We have had some reports from members that their local council officers have been quite understanding and flexible regarding the timings and have offered additional time because of the issues with getting results from courses. This is not an official policy, however. The primary advice is to act immediately though, it is best not to be in the situation where you need to rely on someone’s flexibility.
We have negotiated faster online exam results to protect you from delays
If you are planning to do an online course, we have become aware that there was a five day wait to book the exam, then a 10-day delay to get the result. If for some reason you did fail, it would then be another five-day wait to book the exam and 10 day wait to get the re-sit result. This could be 30 days. This would take us over the deadline to extend our transitional licenses even if we first applied for the exam at the beginning of February.
We spoke with RSPH who administer the online exams, and we highlighted how this situation could put us in a situation where people could end up unlicensed.
After listening to our feedback, they have agreed that if anyone fails the exam, they will get that result back within three days instead of ten and they will allow you to book a resit within three days instead of five. This six-day turnaround is a significant improvement on 30 but please don’t delay. It is unlikely that you will fail the exam but everyone can have bad days and so it was important that we protected you from this situation as much as possible.
RSPH also acknowledged the need to turn around positive results as quickly as possible, something they are actively engaged in doing.
Wales community webinar
We will be organising a community webinar in the coming weeks as a chance to update colleagues in Wales on what has been happening behind the scenes, we will take stock on the situation and, importantly, we want to hear your experiences so we can include these in plans for the way forward.
