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Issue: 68 - Aug 15, 2014
MRSA: A New OSHA Concern: Looking at Employee's Health, Effects on Clients and Medical Privacy Concerns
By: Chery F. Kendrick, DVM, MPVM, MLT, CFS
Kendrick Technical Services, LLC

There are many aspects of our workplace that fall under OSHA. We are constantly aware of the OSHA is a part of every aspect of our work lives. Each and every day we see safety issues in our practices that are a part of our general workplace protocol. I know you can sit here and list at least 10 things that are OSHA related, such as: labels we must have, the charts and warnings, the Personal Protective Equipment, and training and warnings about different chemicals we might use that could possibly pose a hazard to our staff if used inappropriately. We are even made aware of the potential for slip fall hazards, signage needed for that, and always ergonomics especially the dangers associated with improper lifting.

But have you ever thought of a potential hazard that may come from yours and your employees’ health? How about their partners’ health status? Or other family members health status? Ever think about what is brought into your clinic that can pose a potential hazard to you, your staff, your employees and your patients and clients?

(Keep in mind OSHA isn’t concerned with our patients, that other organizations, however we are primarily concerned with the care and safety of our patients.)

Then there is the all-important question of privacy. What is the fine line between personal privacy and government regulatory concern?

And that brings us to a public health issue that is being seen in our clinics and so needs to be addressed.

MRSA: an interesting microorganism first that we hear about in the media primarily with humans. However we also see in our patients. Traditionally the MRSA in animals are different strain than those of concern in humans, and do not pose a zoonotic threat. However an interesting phenomenon is occurring with human strain of MRSA.

We are seeing reverse zoonotic transmission of human strain MRSA being transmitted to our patients, which is then transmitted to a human (zoonotic transmission). We have of course been aware of some transmission of human strain MRSA from our patients to members of the staff when the animals are presented, however what about a case of one of your staff having active MRSA infection and transmitting it to one of your patients, who then transmits it to the owner, or the owners kids, or the owners infirm grandma who lives with them and is immunocompromised?

Have you thought about This potential? Well we need to as it is occurring, and we need to approach it cautiously and judiciously as it is ripe with potential for trampling on some serious legal issues.

Here is the best, safest route for clinics to take: ensure you have a protocol in place for proper use of PPE (Personal Protective Equipment) especially the use of gloves, And include a discussion of what to do if employee has an open lesion. (See link at bottom to get a copy of policy I developed for my OSHA consulting clients).

Infectious disease control in our practice should cover open lesions, stating that it is a requirement to cover any open lesion and wear gloves when dealing with patients, or any potentially infectious materials such as cleaning cages, cleaning exam rooms, running lab tests, etc.

This way we are protecting the employee with the active lesion from having exposure to infectious agents, but this would also protect our patients and other employees, as well as clients, from possible transmission of some serious bacteria including MRSA.

The question then becomes does this cover our potential liability, and limit our exposure, or do we need to go further and require that any employee with active MRSA lesion or who has a family member with active MRSA notify us so we can be vigilant about their use of PPE and perhaps limit their job duties to protect them, the rest of the staff as well as our patients and clients?

This really is a case by case, clinic by clinic decision, in my professional opinion, but I would say to carefully think about it, and even check with your HR lawyer or practice lawyer. Let me give you a case study then I will ask you to tell me what You think.

Case Study:

Patient is a white Maltese dog who is brought back in ten days after being seen for annual exam and grooming with an open, draining wound. Client declares during history while you are examining the wound that her mother’s physician would like you to test this wound for MRSA as she has recently been diagnosed with a MRSA wound on her arm. Her mom is older and lives with them and the dog spends most of the time cuddled up with her mom, and the lesion her mother developed is on the same arm that the pup sleeps on. When you take the dog to the back to culture the wound the groomer comes into the area, says hi to the dog and asks what’s up? When you tell her, she responds by saying to the dog: “Aww it’s OK buddy! I have an owie too! She then shows you an open lesion on her hand that she declares is ‘MRSA that keeps coming back’. And then says: “Oh gosh! That little nick turned big didn’t it?” When you ask for clarification she indicates that during grooming she nicked the pup but it didn’t seem like a big deal. You asked her does she wear gloves while grooming dogs and she states heck no! They would just get in the way.

So, what would You do now?

A culture was taken of the open lesion of the dog and sent to the lab. Lab report indicates positive for MRSA with the DNA report stating 95% compatibility in typing as the client MRSA assay.

The timeline of infections can be interpreted as groomer transmitting MRSA to patient who then transmitted it to owner/client.

Scary, right? So this brings up several points.

  1. What is the risk for the other employees if a staff member has an open lesion that's MRSA?
  2. What is the risk for our patients?
  3. What is our risk for our clients?
  4. What protocol do we need to put in place regarding open lesions?

Our protocol for the clinic should say that if you have an open lesion, keep it covered, and wear gloves for your protection as well as the protection of your colleagues and our patients.

We may also choose to include that if you or any of your family members are positive for MRSA, please let your supervisor know so that we can help you make decisions about your work duties and ensure you are wearing gloves. Bottom line: clear communication regarding potential for MRSA zoonotic transmission as well as reverse-zoonotic transmission and development of good infectious disease prevention program incorporating this information and proper use of PPE is essential.

So tell me, what would you do? How do you feel about talking to your employees about their health issues, about things like MRSA infections, or about their partners and other family members?

Just how comfortable do you feel talking to your employees about their personal medical history?

I am willing to bet that this is a very uncomfortable thing for most of us, and something we're not used to doing.

Do me a favor and tell me how you feel. Please give me your opinion on this issue. Send me an email and tell me how you would handle this, and if you think we have a serious concern here.

Write to me at

And click on our link: to sign up for our newsletter and get a free sample protocol to use!

As always please feel free to contact me with any questions or concerns.

Thank you, and stay safe out there.



Chery F. Kendrick, DVM, MPVM, MLT, CFS is a writer, educator, speaker and consultant. She is the nation’s leading veterinary regulatory control and OSHA expert.  Her time spent in Washington D.C.  as an  advocate for  the veterinary profession with OSHA and other regulatory agencies has resulted in many positive compliance changes for our industry. Her manuals and training programs are used by clinics and animal care facilities nationwide. She has the only GHS compliance program specifically for the veterinary practice and designed the most widely used Compassion Fatigue Prevention program used nationwide. She speaks at association meetings and conferences across the country as well as holds workshops and retreats in her beautiful Smokey Mountains of Eastern TN. H er well attended workshops are constantly praised as powerful resources for veterinarians, and their practice managers and staff. Her new Website promises to be an exciting addition to the world of online resources for the veterinary practice. Watch as it grows this summer with On-Demand Webinars!

For information on Dr. Kendrick’s onsite OSHA consulting services, manuals, training programs, charts and safety supplies please visit the Website or call her at 865-405-4255 or email:

Watch our new website as it updates to include On-Demand Webinars and Staff Training! Check us out at:

Need a speaker at your meeting this summer? We are scheduling now for our nationwide tour! Be sure to call to get your clinic or meeting on our schedule! 865-405-4255