NDIS Infection Control Policy: Requirements for Disability Service Providers

Why Infection Control Matters in SIL

People with disability are often more vulnerable to infectious illness than the general population. Many NDIS participants have immune system conditions, chronic health issues, or take medications that reduce their resistance to infection. In a shared SIL house where participants live together and share common spaces, an infection that enters the house can spread rapidly and cause serious illness.

Support workers are the primary vector through which infections enter SIL settings. Workers who work across multiple houses, attend work while unwell, or do not consistently apply standard precautions can unknowingly introduce respiratory viruses, gastroenteritis, influenza, and other infectious illnesses into the homes of people who are most at risk of serious complications.

COVID-19 demonstrated this vulnerability in devastating detail. The disability sector experienced some of the highest COVID-19 mortality rates of any sector during the pandemic, with SIL settings particularly affected. The lessons learned — and the regulatory expectations established — during COVID-19 have permanently elevated infection control standards for NDIS providers.

Practice Standard Outcome 4.5

NDIS Practice Standard Outcome 4.5 (Safe environment) encompasses the full range of environmental safety obligations for registered providers, with infection control as a specific and prominent component. The quality indicators for the infection control elements of Outcome 4.5 require that providers:

• Have a documented infection control policy that reflects current best practice
• Apply standard precautions consistently across all support activities
• Provide workers with appropriate PPE and training in its correct use
• Have documented outbreak management procedures that workers can implement
• Provide all workers with infection control training at induction and regularly thereafter
• Maintain appropriate cleaning and disinfection protocols for participant living environments
• Have arrangements to manage workers who present to work with infectious illness

Outcome 4.5 also intersects with the emergency management requirements under Outcome 2.2, as infectious disease outbreaks are a specific category of emergency that SIL providers must plan for.

Standard Precautions in SIL Settings

Standard precautions are the baseline infection prevention practices that must be applied in all care situations — regardless of whether a participant is known to have an infectious illness. They are based on the principle that all blood, body fluids, secretions, and non-intact skin should be treated as potentially infectious.

In a SIL context, standard precautions include:

• Hand hygiene — before and after all personal care tasks, after contact with any body fluid or contaminated surface, after removing gloves
• Gloves — worn for all tasks involving contact with blood, body fluids, mucous membranes, or non-intact skin
• Aprons and gowns — worn where there is a risk of clothing contamination
• Safe sharps handling — needles and lancets never recapped, placed directly into sharps containers, never disposed of in general waste
• Respiratory hygiene — workers and participants encouraged to cover coughs and sneezes, use tissues, and perform hand hygiene after respiratory secretion contact
• Linen handling — soiled linen handled minimally, not shaken, bagged and washed in hot water separately from unsoiled linen
• Spill management — blood and body fluid spills cleaned up promptly using appropriate disinfectant and PPE

Standard precautions must be applied consistently — they are not a response to a known infection risk, they are the routine baseline that prevents unknown infections from spreading.

PPE Requirements

Personal protective equipment (PPE) protects workers from exposure to infectious material. As the PCBU, your organisation has a duty under WHS legislation to identify PPE requirements for the tasks your workers perform and to supply appropriate PPE at no cost to workers.

Your infection control policy must specify the PPE requirements for different activities and scenarios:

• Personal care (standard) — disposable gloves; apron if splash risk
• Wound care — disposable gloves; apron; mask if risk of splatter
• Medication administration (invasive) — disposable gloves; additional PPE as required by medication administration protocol
• Infectious participant (respiratory illness) — surgical mask at minimum; gloves; eye protection if coughing participant; consider N95 respirator for high-risk situations
• Infectious participant (gastrointestinal illness) — gloves; apron; mask if vomiting; additional gowning for close personal care
• Cleaning and disinfection — gloves; apron; eye protection when using concentrated disinfectants

PPE must be stocked in adequate quantities in each SIL house. Running out of PPE during an outbreak is an unacceptable risk. Your policy should specify the minimum stock levels and the process for restocking before supplies are exhausted.

Hand Hygiene

Hand hygiene is the single most effective infection prevention measure. Most healthcare-associated and care setting infections are transmitted via the hands of workers — not via aerosols, surfaces, or other routes. A culture of consistent, correct hand hygiene in your SIL houses will prevent more infections than almost any other single intervention.

Your infection control policy should specify the five moments for hand hygiene (based on the World Health Organization's framework, adapted for residential settings):

1. Before touching a participant
2. Before any clean or aseptic care task
3. After any risk of body fluid exposure
4. After touching a participant
5. After touching a participant's environment

Both soap and water handwashing and alcohol-based hand rub (ABHR) are effective for most situations. Soap and water must be used when hands are visibly dirty or contaminated with body fluids, and when caring for a participant with gastrointestinal illness caused by Clostridioides difficile (C. diff) or norovirus, as ABHR is not effective against these pathogens. Your policy should specify when soap and water is required rather than ABHR.

Alcohol-based hand rub should be available at the point of care in each SIL house — in bathrooms, at the front door, and in the kitchen at minimum. Workers should not have to leave the participant's room to perform hand hygiene, as this creates a compliance barrier.

Outbreak Management

An outbreak is defined as two or more linked cases of the same illness in a setting within a defined time period. In a SIL house with three or four participants, a single case of gastroenteritis or respiratory illness should be treated as a potential outbreak until proven otherwise, because the shared living environment creates high transmission risk.

Your outbreak management procedure should specify:

• Who declares an outbreak and at what threshold
• Notification requirements — NDIS Commission, state or territory health department, participant families
• Isolation arrangements for ill participants within the house
• Enhanced PPE requirements for the outbreak period
• Cohort staffing — assigning specific workers to the affected house and preventing them working in other houses during the outbreak
• Enhanced cleaning and disinfection protocols during the outbreak
• Management of ill workers — stay-at-home requirements, return-to-work criteria
• Outbreak resolution criteria — when can normal procedures resume?
• Outbreak documentation — what records must be kept?

COVID-19-specific guidance should remain in your policy as a named infectious disease with its own response framework, given the ongoing nature of COVID-19 as an endemic infection. Your policy should also reference influenza and gastrointestinal illness as the most frequently occurring outbreak scenarios in SIL settings.

Cleaning and Disinfection Protocols

Regular cleaning and disinfection of the SIL house environment is a critical component of infection prevention. Your infection control policy must address both routine cleaning (daily household cleaning that reduces the build-up of organic material and general contamination) and enhanced disinfection (specific disinfection of high-touch surfaces during or following an infectious illness episode).

Routine cleaning should cover:

• Daily cleaning of bathrooms and toilets (using a disinfectant cleaner)
• Regular cleaning of kitchen surfaces, handles, and appliances
• Regular cleaning of high-touch surfaces (door handles, light switches, remote controls)
• Regular laundering of linen and towels at appropriate temperatures

Enhanced disinfection during or after an illness episode requires use of a TGA-listed disinfectant (listed on the TGA's Australian Register of Therapeutic Goods) appropriate to the pathogen involved. During COVID-19, this meant using a product with demonstrated efficacy against coronaviruses. Your policy should specify which disinfectant products are approved for use, and ensure Safety Data Sheets are available for all cleaning chemicals used in the house.

Staff Training Requirements

All workers must receive infection control training as part of their induction and at regular intervals thereafter. Training must cover the content of your infection control policy, correct hand hygiene technique, correct donning and doffing of PPE, spill management, and the procedures to follow when a participant is unwell.

The Australian Commission on Safety and Quality in Health Care (ACSQHC) offers the Hand Hygiene Australia modules, and several registered training organisations (RTOs) offer infection control units as part of Certificate III and IV qualifications. Online modules can satisfy the knowledge component, but where possible, practical demonstration of correct PPE use and hand hygiene technique is strongly recommended.

Training records must be retained in your training register, recording the date, content, and delivery method. Where workers complete formal qualifications that include infection control units, a copy of the transcript or certificate should be retained.

What Auditors Check

During a certification audit against Outcome 4.5, auditors will typically request: your infection control policy, your training register (verifying all workers have completed infection control training), evidence of PPE stocks and records, and any outbreak management records from incidents in the review period. They may also conduct a physical inspection of SIL houses, checking for adequate hand hygiene supplies, appropriate PPE storage, and evidence of regular cleaning routines.

Worker interviews commonly include questions about what personal protective equipment they use for personal care tasks and why, what they would do if a participant developed symptoms of gastroenteritis, and when they should use soap and water rather than hand rub. A worker who cannot answer these questions raises concerns about the effectiveness of your infection control training program.

Common audit findings include: policies not updated since COVID-19 to reflect current best practice, training registers showing workers have not completed infection control training at induction, no evidence of PPE stocks in houses, and workers who cannot describe the steps for donning and doffing PPE correctly.