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.
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.
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:
- Change the name of the standard from Blood Borne Pathogens to Blood Borne Viruses to reflect the current language.
- 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.
- 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.
- 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?
This consultation will be open until Friday, November 12, 2021.