POLICY FOR THE CARE OF PATIENTS KNOWN, SUSPECTED OR AT RISK OF HAVING CREUTZFELDT JACOB DISEASE (CJD) v5 IC 07 Version Number: Version 5 Issued Date: January 2014 Review Date: January 2017 Sponsoring Director: Prepared By: Directors of Nursing NHS North Durham, NHS Darlington, NHS Durham Dales, Easington and Sedgefield (DDES) Clinical Commissioning Groups (CCGs) Lead Infection Prevention and Control Nurse Consultation Process: Members of Health and Social Care Health Care Associated Infection (HCAI) Assurance Group Document History Version 1 2 3 4 Date June 2005 June 2007 June 2009 July 2011 5 Jan 2014 Significant Changes * *Reviewed *Reviewed Update with new guidance issues January 2011question on page 7 to be asked of all patients undergoing an endoscopy. *None POLICY VALIDITY STATEMENT This policy is due for review on the latest date shown above. After this date, policy and process documents may become invalid. Policy users should ensure that they are consulting the currently valid version of the documentation. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 1 of 18 EQUALITY IMPACT ASSESSMENT STATEMENT Audit Assessment Date Result Risk Audit 14.01.2014 Risks identified and risk assessment included at Appendix 1 Equality Audit 14.01.2014 No or very low potential for discrimination Human Rights Audit 14.01.2014 No breach of Human Rights H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 2 of 18 POLICY FOR THE CARE OF PATIENTS KNOWN, SUSPECTED OR AT RISK OF HAVING CREUTZFELDT JACOB DISEASE (CJD) v4 Contents Section Title Page 1 Introduction 2 Definitions 3 Care of Patients Known, Suspected or At Risk of Having Creutzfeldt Jacob Disease 4 Duties And Responsibilities 5 Implementation 6 Training Implications 7 Documentation 8 Monitoring, Review And Archiving 9 Equality Analysis 4 5 5 11 12 12 13 14 14 Appendices 1 Risk Assessment H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 18 Page 3 of 18 POLICY FOR THE CARE OF PATIENTS KNOWN, SUSPECTED, OR AT RISK OF HAVING CREUTZFELDT JACOB DISEASE (CJD) v4 1. Introduction NHS North Durham, Darlington and DDES CCGs aspire to the highest standards of corporate behaviour and clinical competence, to ensure that safe, fair and equitable procedures are applied to all organisational transactions, including relationships with patients, their carers, public, staff, stakeholders and the use of public resources. In order to provide clear and consistent guidance, NHS County Durham and Darlington will develop documents to fulfil all statutory, organisational and best practice requirements and support the principles of equal opportunity for all. Transmissible Spongiform Encephalopathy’s (TSE) are a group of diseases which can occur in both people and animals. The diseases are characterised by degeneration of the nervous system and are invariably fatal. Classical CJD is the commonest form of the human TSEs but is still rare. There is no obvious cause in the majority of cases but in the past 1% have been transmitted as a result of medical treatments such as human pituitary growth hormone injections, corneal transplants and brain surgery involving contaminated instruments. In 1996, the National CJD Surveillance Unit identified a form of CJD that differed from previously recognised types of the disease. The patients were younger, their symptoms were different and the appearance of the brain was not the same as in the classical form of CJD. The disease was initially labelled as new variant CJD (nvCJD) and is now known as variant CJD (vCJD). The precise nature of the agent, which causes either type of CJD, is not known but it is presumed to be an abnormal form of a prion, a protein distributed throughout nature and which is found in the tissues of healthy people and animals. It is believed that prions can cause disease when they become altered in shape by folding in an abnormal way. This abnormally shaped protein then influences the normal prion proteins to alter their shape and it is the accumulation of this altered prion protein which causes destruction of nervous tissue and the clinical manifestations of the disease. Classical CJD is thought to only affect the central nervous system and so brain, spinal cord and eyes are thought to be potentially infectious. Variant CJD as well as affecting the central nervous system has also been detected in lymphatic tissue such as tonsil and appendix. It is therefore believed that vCJD poses a greater potential risk of person to person spread in health care settings than classical CJD. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 4 of 18 The Government’s Spongiform Encephalopathy Advisory Committee (SEAC) concluded that the most likely explanation for the emergence of vCJD was that it had been transmitted to people through exposure to Bovine Spongiform Encephalopathy (BSE). 1.1 Status This policy is an Infection Prevention and Control policy. 1.2 Purpose and scope . This guidance applies to healthcare workers involved in the management and care of patients with known, suspected or who are at risk of developing, CJD within NHS North Durham, Darlington and DDES CCGs. It would be good practice for this policy to be adopted by external contractors. 2. Definitions The following terms are used in this document CJD: Creutzfeldt Jacob Disease TSE: Transmissible Spongiform Encephalopathy vCJD: Variant CJD Prion: A protein distributed throughout nature and which is found in the tissues of healthy people and animals BSE: Bovine Spongiform Encephalopathy 3. Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease 3.1 Summary For patients known, suspected or at risk of classical CJD there are no special precautions that need to be taken for surgical instruments coming into contact with tissues other than brain, the spinal cord, the eye or olfactory epithelium. For patients known, suspected or at risk of vCJD there are no special precautions that need to be taken for surgical or dental instruments coming into contact with tissues other than the brain, the spinal cord, the eye, the olfactory epithelium or lymphoid tissue. Affected tissue has been detected in the tonsil, appendix, lymph node, spleen, thymus, adrenal gland and rectum of vCJD patients. . In most routine clinical contact no additional precautions are needed for the care of patients in the risk groups (Table 1). However, when certain invasive interventions are performed, there is the potential for exposure to the agents of TSEs. In these situations it is essential that control measures are in place to prevent the spread of infection. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 5 of 18 In general it is not possible to identify specific risk groups for the iatrogenic transmission of vCJD. However, the CJD Incidents Panel may identify individual patients who have been exposed to vCJD and advise them to inform clinicians in the event of needing surgery. Decisions on whether instruments can be reprocessed will be made on the basis of type of tissues previously encountered. This decision will be made on an individual patient basis by the Clinician in charge of that patient following consultation with the consultant microbiologist. 3.2 Infection Control and CJD The epidemiological evidence to date does not suggest that, in the majority of situations with CJD patients, there is need for particular precautions beyond those that should be used as standard for other patients. The use of routine standard infection control precautions will minimise the exposure of individuals involved in the healthcare of patients who have, or may develop, a TSE and protect them from the very remote possibility of infection. When considering measures to prevent transmission to patients or staff in the healthcare setting, it is useful to make a distinction between symptomatic patients, i.e. those who fulfil the diagnostic criteria for definite, probable or possible CJD or vCJD, and asymptomatic patients, i.e. those with no clinical symptoms, but who are potentially at risk of developing one of these diseases, i.e. having a medical or family history which places them in one of the risk groups. Table 1 below details the classification of the risk status of symptomatic and asymptomatic patients. Table 1 Creutzfeldt Jacob Disease Patient groups Symptomatic patients Patients ‘at increased risk’ from genetic forms of CJD • Patients who fulfil the diagnostic criteria for definite, probable or possible CJD or vCJD; • Patients with neurological disease of unknown aetiology, who do not fit the criteria for possible CJD or vCJD, but where the diagnosis of CJD is being actively considered. • Individuals who have been shown by specific genetic testing to be at significant risk of developing CJD; • Individuals who have a blood relative known to have a genetic mutation indicative of genetic CJD; • Individuals who have or have had two or more blood relatives affected by CJD or other prion disease. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 6 of 18 Patients identified as ‘at increased risk’ of CJD/vCJD through iatrogenic exposures • Recipients of hormone derived from human pituitary glands, e.g. growth hormone, gonadotrophin. In the UK the use of humanderived gonadotrophin was discontinued in 1973, and use of cadaver-derived human growth hormone was banned in 1985. However, use of human-derived products may have continued in other countries after these dates. • Individuals who underwent intradural neurosurgical or spinal procedures before August 1992. These patients may have received a graft of human-derived dura mater and should be treated as being ‘at increased risk’ unless evidence can be provided that humanderived dura mater was not used. Patients who received a graft of human-derived dura mater before August 1992 are ‘at increased risk’ of transmission of sporadic CJD. • Individuals who have had surgery using instruments that had been used on someone who went on to develop CJD/vCJD, or was ‘at increased risk’ of CJD/vCJD; • Individuals who have received an organ or tissue from a donor infected with CJD/vCJD or ‘at increased risk’ of CJD/vCJD; • Individuals who have been identified prior to high risk surgery as having received blood or blood components from 80 or more donors since January 1980; • Individuals who have received blood from someone who went on to develop vCJD. Recipients of ocular transplants, including corneal transplants, are not considered to be ‘at increased risk’ of CJD/vCJD. In most routine clinical contact, no additional precautions are needed for the care of patients in the risk groups. However, when certain invasive interventions are performed, there is the potential for exposure to the agents of TSEs. In these situations it is essential that control measures are in place to prevent the iatrogenic transmission of TSEs. GPs are asked to record their patients’ CJD/vCJD risk status in their primary care records. The GP should also include this information in any referral letter should the patient require surgical, medical or dental procedures. 3.3 All patients for endoscopy This guidance is taken from Transmissible Spongiform Encephalopathy Agents: Safe Working and the Prevention of Infection Annex J in Appendix E 16 July 2009 which gives further background and detail. Recommendations for all patients undergoing surgery or endoscopy (including rigid sigmoidoscopy) All patients about to undergo any elective procedure or emergency or endoscopic procedure should be asked the question, H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 7 of 18 ‘Have you ever been notified that you are at increased risk of CJD or vCJD for public health purposes?’ Based on the patient’s response actions should be taken as outlined below Patient’s response: NO Surgery or endoscopy should proceed using normal infection control procedures unless the procedure is likely to lead to contact with high risk tissue. YES Please ask the patient to explain further. The Consultant Microbiologist in the Local Foundation Trust should be consulted before any procedure is undertaken for advice, as special infection control precautions are necessary for all surgery or endoscopy involving patients at risk of CJD or vCJD. The patient’s response should be recorded in their medical notes for future reference. Patient unsure Surgery or endoscopy should proceed using normal infection control procedures unless the procedure is likely to lead to contact with high risk tissue. If the procedure is likely to lead to contact with high risk tissue please contact the Consultant Microbiologist for advice. 3.4 Care of patients in the community defined in Table 1 Procedures Available epidemiological evidence does not suggest that normal social or routine clinical contact with a CJD or vCJD patient presents a risk to healthcare workers, relatives or others in the community. Body Fluids At present, there is no evidence of infectivity in saliva, body secretions or excreta. Although abnormal prion protein has not been detected in the Cerebrospinal Fluid (CSF) in either sporadic or variant CJD in the main, most infectivity is likely to be concentrated in the central nervous tissue. In vCJD, infectivity is also likely to be present in lymphoid tissue, albeit at a lower level. It is important to ensure that only professionals, aware of the hazards, carry out invasive procedures involving body fluids that may lead to contact with infective tissue. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 8 of 18 Invasive Medical/Surgical Procedures and Specimen Labelling Because of the unusual resistance to destruction of the TSE agents, singleuse disposable equipment should be used wherever practicable, and all other items of equipment contaminated whilst obtaining specimens should be destroyed by incineration. Blood and biopsy specimens from patients defined in Table 1 should only be taken by trained personnel who are aware of the hazards involved. The collection of blood specimens should involve the same precautions used for all work of this type with any patient i.e. avoidance of sharps injuries and other forms of parenteral exposure, and the safe disposal of sharps and contaminated waste in line with the Safe Disposal of Sharps and Waste Policy. Samples should be marked with a ‘Biohazard’ label and it is advisable to inform the laboratory in advance that a specimen is being sent. Patient confidentiality must be maintained, do not write ‘CJD’ on the card. Spillages The infectious agent associated with TSEs is unusually resistant to inactivation techniques. Dilution is the most important element in cleaning up spillages. Exposure to high-concentration (10,000 ppm available chlorine) sodium hypochlorite for one hour is known to be effective. Although its use is unlikely to be practical in any clinical environment or other care setting, since it is highly corrosive to many surfaces, it can be used in exceptional circumstances to clean up spillages of high-risk material, e.g. CSF. Therefore, standard infection control precautions should be followed to clear up spillages in primary care including spillages of blood. Potentially infectious materials should be removed using absorbent material, and any waste disposed of as hazardous waste, in line with policy. Disposable gloves and an apron should be worn when removing such spillage(s), goggles should be worn if there is a risk of splashing and disposed of as hazardous waste. For spillages of large volumes of liquid, absorbent material should be used to absorb the spillage, for which a number of proprietary absorbent granules are available. Disposal of Waste General guidance on the safe management of clinical waste is given in the Department of Health’s guidance document Health Technical Memorandum 07-01: Safe Management of Healthcare Waste, available at http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPo licyAndGuidance/DH_063274. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 9 of 18 According to this guidance, ‘Waste known or suspected to be contaminated with transmissible spongiform encephalopathy (TSE) agents, including CJD, must be disposed of by high temperature incineration in suitable authorised facilities’. Additional guidance on the management of TSE-infected waste is given in the Department of Health’s Transmissible spongiform encephalopathy: Safe working and the prevention of infection. The ACDP TSE Working Group have considered the disposal of clinical waste, and have agreed that tissues and contaminated materials such as dressings and sharps, from patients with, or ‘at increased risk’ of, CJD/vCJD, should be disposed of as in the following table: Table 4b Disposal of clinical waste from patients with, or ‘at increased risk’ of, CJD or vCJD Diagnosis of CJD High or medium risk tissue * Low risk tissue and body fluids** Definite Incinerate Normal hazadrous waste disposal Probable Incinerate Normal hazardous waste disposal ‘At increased risk’ Incinerate Normal hazardous waste disposal * High or medium risk tissues are highlighted in section 3.1 of this policy ** Tissues and materials deemed to be low risk include body fluids such as urine, saliva, sputum, blood, and faeces. Blood from vCJD patients is considered to be low risk except when transfused in large volumes. Bed Linen Bed linen can be washed in domestic washing machines in patients’ own homes at the highest temperature the fabric can withstand. Occupational Exposure Although cases of CJD/vCJD have been reported in healthcare workers, there have been no confirmed cases linked to occupational exposure. However, it is prudent to take a precautionary approach. The highest potential risk in the context of occupational exposure is from exposure to high infectivity tissues through direct inoculation (e.g. as a result of ‘sharps’ injuries, puncture wounds or contamination of broken skin), and exposure of the mucous membranes (e.g. conjunctiva). Compliance with standard infection control precautions will help to minimise risks from occupational exposure. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 10 of 18 Healthcare personnel, who work with patients with definite, probable or possible CJD or vCJD, or with potentially infected tissues, should be appropriately informed about the nature of the risk and relevant safety procedures. For any accident involving ‘sharps’, or contamination of abrasions with blood or body fluid(s), wounds should be gently encouraged to bleed, gently washed (avoid scrubbing) with warm soapy water, rinsed, dried and covered with a waterproof dressing, or further treatment given appropriate to the type of injury. Splashes into the eyes or mouth should be dealt with by thorough irrigation. The accident should be reported to your manager and the Management of Potential Exposure to Blood and Body Fluid Policy followed. 4. Duties and Responsibilities 4.1 Accountable Officer The accountable officer has overall responsibility for the strategic direction and operational management, including ensuring that CCG process documents comply with all legal, statutory and good practice guidance requirements. 4.2 Director of Nursing The Director of Nursing is the sponsoring director for this document and is responsible for ensuring that: 4.3 arrangements are in place to manage infection prevention and control including the risks from managing patients known, suspected or at risk of having CJD. In addition the Director of Nursing is responsible for ensuring that the policy is drafted, approved and disseminated in accordance with the ‘Policy for the Development and Approval of Policies’. The necessary training and education needs and methods to implement this document are identified and resourced. Mechanisms are in place for the regular evaluation of the implementation and effectiveness of this document. Lead Infection Control Nurse The Lead Infection Control Nurse will: update the policy and all supporting documents; ensure the policy is taken to members of Health and Social Care HCAI Group for comment; monitor the effectiveness of this policy and its procedures through audit; H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 11 of 18 4.4 provide support and advice to staff on decontamination of equipment; deliver training to clinical staff on the procedures and processes laid out in the policy through training. Title of any relevant officers None. 4.5 All Staff All staff, including temporary and agency staff, are responsible for: compliance with relevant process documents. Failure to comply may result in disciplinary action being taken; co-operating with the development and implementation of policies and procedures as part of their normal duties and responsibilities; identifying the need for a change in policy or procedure as a result of becoming aware of changes in practice, changes to statutory requirements, revised professional or clinical standards and local/national directives, and advising their line manager accordingly; identifying training needs in respect of policies and procedures and bringing them to the attention of their line manager; attending training / awareness sessions when provided. 5. Implementation 5.1 This policy will be available to all Staff for use. 5.2 All managers are responsible for ensuring that relevant staff within their own directorates and departments have read and understood this document and are competent to carry out their duties in accordance with the procedures described. 6. Training Implications It has been determined that there are no specific training requirements associated with this policy/procedure. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 12 of 18 7. Documentation 7.1 Other related policy documents None. 7.2 Legislation and statutory requirements Department of Health (2011) (part 4) Infection control of CJD, vCJD and other human prions diseases in healthcare and community settings. Department of Health (2011) Annex J Assessment to be carried out before surgery and/or endoscopy to identify patients with or at increased risk of CJD or vCJD. 7.3 Best practice recommendations None. 7.4 References Department of Health (2005). Transmissible spongiform encephalopathy agents: safe working and the prevention of infection. Guidance from the Advisory Committee on Dangerous Pathogens and the Spongiform Encephalopathy Advisory Committee. London. DH. Department of Health (2006). Health Technical Memorandum 07-01: Safe Management of Healthcare Waste. London. DH. Department of Health (2006). The Health Act 2006, Code of Practice for the Prevention and Control of Health Care Associated Infections. London. DH. Department of Health (2011) Infection control of CJD,vCJD and other human prions diseases in healthcare and community settings. (part 4). London. DH. Department of Health (2011). Annex J Assessment to be carried out before surgery and/or endoscopy to identify patients with or at increased risk of CJD or vCJD. London. DH. Health Protection Agency (2009). Letter to Clinical Groups – Pre-surgical risk assessment for variant Creutzfeldt-Jakob Disease (vCJD) risk in patients undergoing neurosurgery, neuro-endoscopy and eye surgery. London. HPA. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 13 of 18 8. Monitoring, Review and Archiving 8.1 Monitoring The Director of Nursing as sponsoring director will agree with the Lead Infection Prevention and Control Nurse a method for monitoring the dissemination and implementation of this policy. Monitoring information will be recorded in the policy database. 8.2 Review 8.2.1 The Director of Nursing will ensure that each policy document is reviewed in accordance with the timescale specified at the time of approval. No policy or procedure will remain operational for a period exceeding three years without a review taking place. 8.2.2 Staff who become aware of changes in practice, changes to statutory requirements, revised professional or clinical standards and local/national directives that affect, or could potentially affect policy documents, should advise the sponsoring director as soon as possible, via line management arrangements. The sponsoring director will then consider the need to review the policy or procedure outside of the agreed timescale for revision. 8.2.3 Whether or not the review results in changes to the document, the author will inform the Policy and Corporate Governance Lead who will schedule the revised policy for the next appropriate policy group meeting. Following reapproval the policy will be re-issued under the next ‘version’ number. 8.2.4 For ease of reference for reviewers or approval bodies, changes should be noted in the ‘document history’ table on the front page of this document. NB: If the review consists of a change to an appendix or procedure document, approval may be given by the sponsoring director and a revised document may be issued. Review to the main body of the policy must always follow the original approval process. 8.3 Archiving The Policy and Corporate Governance Lead will ensure that archived copies of superseded policy documents are retained in accordance with Records Management: NHS Code of Practice 2009. 9. Equality Analysis The tables below summarise reviews with respect to: Strategic and operational risks, including risks to health and safety. Current equality and diversity legislation. Rights under the European Convention on Human Rights. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 14 of 18 9.1 Risk Audit Risk Audit for RISK CATEGORIES 1 2 3 4 5 6 7 8 Risks relating to organisational objectives Risks to patient experience/outcome Risk to or from service/business interruption Risks relating to staffing and competence Financial risks Risks to compliance with inspection/audit standards General risks to organisational reputation Specific health and safety (inc fire) risks to persons (staff, patients, public, etc) a Location (access, environment, working conditions) b Equipment (medical, electrical, other) c Hazardous substances d Lone working e Moving and handling f Potential to cause undue stress g Anti-social behaviour (violence, harassment, theft) Significant Risks Identified Yes/No Yes Yes No Yes No Yes Yes No No No No No No No No OUTCOME (tick appropriate box) ACTION No significant risks identified Significant risks identified Proceed with ratification process. There is some doubt about whether risks are significant or relevant. Complete a full risk assessment form and action plan for all risks identified. Include in the Appendices – see Appendix 8. Take further advice from appropriate directorate or department. If unresolved, refer to Governance and Assurance Committee. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 15 of 18 9.2 Equality Audit Equality Audit for QUESTION RESPONSE What is the purpose of the proposed policy document (or changes to policy document)? Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) Correct patient management and safety No Who is intended to benefit, and how? Will the proposals involve, or have consequences for, the people the CCGs serve and employ? Is there any reason to believe that people could be affected differently by the proposals, for example in terms of access to a service, or the ability to take advantage of proposed opportunities? Is there any evidence that any part of the proposals could discriminate unlawfully, directly or indirectly, against any section of the population? Is the proposed policy likely to affect relations between certain groups of people, for example because it is seen as favouring a particular group or denying opportunities to another? Is the proposed policy likely to damage relations between any particular group(s) of people and the CCG? No No No No OUTCOME (tick appropriate box) Potential for discrimination is very low or non-existent Potential for discrimination exists There is doubt about the potential for discrimination Proceed with ratification process. Amend the document as appropriate to clarify exceptions or remove potential. If this is not possible, take further advice from Corporate Services Manager and/or the Equality Lead Manager (HR Department) H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 16 of 18 9.3 Human Rights Audit Human Rights Audit for QUESTION RESPONSE Does the policy document interfere with a Convention right? Could the actions described in the policy document touch on one of the Convention rights? Is there a victim? Are there circumstances where the right can legitimately be limited or interfered with? Does the interference meet the general criteria established by the Strasbourg authorities, ie: The action is prescribed by law It pursues a legitimate aim. It is necessary in a democratic society. No No No No No OUTCOME (tick appropriate box) No rights affected Potential to affect a right has been identified There is doubt about the potential to affect a right. Proceed with ratification process. Amend the document as appropriate to clarify exceptions or remove potential. If this is not possible, take further advice from Corporate Services Manager/Legal Advisers. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 17 of 18 APPENDIX 1 Risk Assessment There is a risk of non-compliance with all infection control policies which would in turn increase the risk of patients acquiring healthcare associated infections (HCAI), the organisation not achieving national targets on HCAI and not complying with inspection audits. These policies are designed to provide a framework to reduce those risks. H:/Infection Control / Policy for the Care of Patients known, suspected or at risk of having Creutzfeldt Jacob Disease (CJD) v5 Page 18 of 18