Uninspected Tattoo/Piercing or Other Personal Service Premises

  • Policy

Category: Control of Infectious Diseases
Subject: Uninspected Tattoo/Piercing or Other Personal Service Premises
Division: Health Protection
Policy Number: CA.82.01.121
Effective Date: August 8, 2016

POLICY STATEMENT

It is the policy of Wellington-Dufferin-Guelph Public Health (WDGPH) that reports or complaints of uninspected home-based premises offering tattooing, body piercing, or other personal services will be investigated by an assigned Control of Infectious Diseases (CID) Public Health Inspector (PHI). However, it is recognized that a PHI does not have the authority to enter a shop operating from a home location without the homeowner’s consent. It is also recognized that businesses advertising on the internet may not post an address to enable the inspector to find the business to complete follow-up.

CID PHIs are guided in their inspections by the provincial Infection Prevention and Control Best Practices for Personal Services Settings (as current) and Infection Prevention and Control in Personal Services Settings Protocol (as current) in accordance with the Ontario Public Health Standards. The PIDAC document Best Practices for Cleaning, Disinfection and Sterilization of Medical Equipment Devices in All Health Care Settings (February, 2010) will also be used as reference information for inspections.

SCOPE

This policy applies to all CID PHIs who conduct inspections of tattoo and body piercing premises.

DEFINITIONS

Home-based – A business which is operated out of the owner’s home.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Procedure:  CA.82.02.121 Uninspected Tattoo/Piercing or Other Personal Service Premises
CA.82.02.102  Personal Services Settings Inspection 
CA.50.01.101 and CA.50.02.101 Documentation Practices
Infection Prevention and Control Best Practices for Personal Services Settings (as current)
Infection Prevention and Control in Personal Services Settings Protocol (as current)
Infection Prevention and Control Practices Complaint Protocol (as current)
Practices for Cleaning, Disinfection and Sterilization of Medical Equipment Devices in All Health Care Settings

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases

APPROVED BY

Director, Health Protection  


Procedure

Category: Control of Infectious Diseases
Subject: Uninspected Tattoo/Piercing or Other Personal Service Premises
Division: Health Protection
Procedure Number: CA.82.02.121
Effective Date: August 8, 2016

PROCEDURE

Upon receiving notification of an uninspected home-based tattoo/body piercing, or other personal service premises (e.g., via public complaint or advertising), the following steps should be taken:

1. Control of Infectious Disease (CID) Public Health Inspector (PHI) will create the operator/premises in Excelicare and start an intake assessment.

2. If the address of the home-based premises is known, a CID PHI will attempt to deliver the letter  Uninspected Tattoo Premises to the operator (See template in CID SharePoint under Outbreaks/Uninspected Piercing or Tattoo Premises Complaints and Investigations Templates/Letter to Operator template). This letter may be modified for another type of personal service offering services from an uninspected home-based premises.

If the physical address of the home-based premises is unknown, the PHI will attempt to email the letter (if possible) or will attempt to contact the operator by telephone (if possible) in order to  get a postal/email address for delivery.

3. The CID PHI will attempt to confirm receipt of the letter via email or telephone call to the operator, if possible.

4. The CID PHI will conduct an internet search to determine if the operator is advertising tattoo/piercing or other personal services online, and if so, will attach this information to the electronic file.

5. The CID PHI will try to contact the operator in order to conduct a site inspection of the premises and related equipment on or before the date listed in the letter provided to the operator. Two inspectors must do the site visit. During the site visit to the premises, the CID PHI will do the following:

  • Identify him/herself to the operator;
  • Take photographs of any observed equipment and supplies available and the layout of the physical location;
  • Inquire whether the premises and/or operator goes by any other name;
  • Inquire whether any tattoos/body piercings or aesthetic services were done at any other addresses or locations. If so, the PHI will attempt to obtain a full list of additional location addresses, including city of operation, dates of operation, approximate number of tattoos/body piercings performed, and will request to see client records;
  • Attempt to obtain an estimate of the number of body piercings/tattoos or other personal services performed at each location;
  • Attempt to obtain an estimate of how long the operator/premises has been in operation;
  • Determine whether an autoclave/sterilizer is available and in use;
  • If applicable, obtain the make, model, and any other information for the unit;
  • If applicable, inquire whether spore testing records are available for review, and if so, the location where the tests are being processed;
  • Determine whether pre-sterilized, pre-packaged, single-use equipment is available, and if so, assess the integrity of packaging and determine whether sterilization expiration dates are current or expired;
  • Verify the operator’s contact information (legal name, address, phone number, email etc.);
  • Inquire whether any tattoo/piercing parties have been offered.  If so, find out where and when; and
  • Determine if the operator(s) has a Facebook page or any other social media sites.

6. The CID PHI will document all photographs taken in their evidence notebook and will document all actions taken in a Hedgehog CSR or Excelicare. All telephone conversations will be documented via electronic charting. A file for the premises should be opened in Excelicare and the file should reference the Hedgehog CSR number.

7. Photographs will be printed and attached to the electronic investigation file in Excelicare.

8. The following client information  will be collected by the PHI from the operator (if available):

  • Name (first and last);
  • Date of birth;
  • Parent name (if applicable);
  • Phone number;
  • Address (permanent and temporary address if applicable); and
  • Date tattoo/piercing done.

9. Information collected will be reviewed with the CID Manager to determine if there was a public risk during the operation of the uninspected premises. If so, a determination will be made by the Medical Officer of Health (MOH) and CID Manager whether it is sufficient to contact identified clients directly, or whether a media advisory is necessary (e.g., if client records are incomplete, if no client records are available, or if client records provided do not match the number of tattoo/piercings or high risk services offered by the premises).

10. If a media release is issued, it will be posted on Wellington-Dufferin-Guelph Public Health’s (WDGPH) website and distributed by the Communications department once approved by the MOH.  (See templates in CID SharePoint under Outbreaks/Uninspected Piercing or Tattoo Premises Complaints and Investigation/Media Release Tattoo – Draft).

  • Ensure that the street name (not house number) or major intersection is included; and
  • The MOH, CID Manager, and Communications team must approve the media release prior to distribution.

11. A physicians’ advisory shall be distributed to all physicians notifying them of potential exposures to bloodborne infections and advising that clients have been advised to seek testing for HIV, hepatitis B, and hepatitis C. (See template in CID SharePoint under Outbreaks/Uninspected Piercing or Tattoo Premises Complaints and Investigation/Physician Advisory Template 2012).  The MOH, CID Manager, and Communications team must approve the physicians’ advisory prior to distribution.

12. The CID Manager will notify Public Health Ontario (PHO)/Ministry of Health and Long-Term Care (MOHLTC)/Public Health Ontario Laboratories (PHOL) that the media release and/or physicians’ advisory has been issued and an investigation has started.

13. The CID PHI shall update the CID team via email and include:

  • The outbreak number for the investigation, operator identifying information (name of operator(s)/premises), known addresses where tattoo and/or piercing services have been offered, etc.);
  • Question and answer sheet for MRP calls; and
  • Client log for home-based tattoo/piercing operation that includes:
  • Caller name;
  • Date/time of phone call;
  • Client name;
  • Phone number;
  • Address of client;
  • Package sent to client (yes/no);
  • Testing done (yes/no); and
  • Calling script for conversations with potential clients of the operator/premises.

(See template in CID Sharepoint under Outbreaks/ Q and A Template and Spreadsheet Template)

14. The CID Manager will notify Clinical Services and the School Health Managers, and will:

  • Provide a copy of the media advisory;
  • Provide a copy of the client log for home-based tattoo/piercing operation;
  • Provide a general advisory for distribution to schools (if applicable); and
  • Request that students who received services from the tattoo/piercer call 4752 for more information.

15. In some cases, a client package will be created and distributed to all identified clients (via client consent records or phone call).  This package must be approved by the CID Manager. (See template in CID SharePoint under Outbreaks/Templates for Uninspected Piercing or Tattoo Premises Complaints and Investigation). This package will include:

  • Letter to client
  • Letter to physician
  • General test requisition for the following tests:
  • Hepatitis B; and
  • Hepatitis C.
  • HIV serology test requisition including the following information:
  • Exposure category “other”;
  • Reason for HIV testing “diagnostic”; and
  • Specimen details “ whole blood, HIV1/HIV2”.
  • Laboratory instructions to physicians for tattoo/body piercing investigation.

NOTEA copy of the client package will be provided to Clinical Services for clients who visit WDGPH Clinical Services to pursue testing (e.g., individuals who do not have a family physician or school health nurse).

16. WDGPH staff are encouraged to collect the following information when interviewing clients:

  • Date tattoo/piercing done
  • Was money paid to the operator?
  • How did you hear about the operator?
  • Where did you get the tattoo/piercing done (location)?
  • Is there any evidence of infection?
  • Have you been tested for HIV/hepatitis B, hepatitis C previously?
  • Have you previously been vaccinated for hepatitis B?
  • Was the equipment/needle opened in front of you?
  • Did you see anyone re-using needles?
  • Were you provided with any aftercare instructions?
  • What school do you/your child attend?

17. The assigned CID PHI will notify Clinical Services of potential test results being returned to WDGPH for clients that decide to pursue testing for hepatitis B/C and HIV.  If results associated with the investigation outbreak number are received by Clinical Services they will be forwarded to the CID team for documentation in the Excelicare investigation file. 

18. WDGPH will follow-up with clients once laboratory paperwork is received and provide interpretation of results and any additional information. This is normally the Clinical Services team if there is a positive result and/or the blood was tested by Clinical Services.

19. When blood testing results associated with an outbreak related to a tattoo or piercing investigation are received by WDGPH, a data entry clerk will provide copies of results to both CID and Clinical Services if MOH is listed on the form as the physician ordering testing. Positive hepatitis B/C or HIV test results will be provided to clients by a Clinical Services team member, in accordance to their policies and procedures. Reports given to CID will be scanned into the Excelicare investigation file.

20. The assigned CID PHI will contact the individual(s) who initiated the original complaint to provide them with general information on the complaint investigation.

21. All laboratory paperwork will be attached to the Excelicare file of the investigation.

RESPONSIBILITIES

CID Manager will:
  • Consult with the MOH to determine if WDGPH will issue a media release to alert the public of the potential health risk if the uninspected tattoo or body piercing premises failed to maintain accurate client records;
  • Send a copy of the media release to the MOHLTC and PHO contact; and
  • Ensure all organizational policies and procedures for personal safety are followed when entering home-based premises.
CID PHIs will:
  • Begin investigations of uninspected home-based tattoo and body piercing premises within 24 hours of receiving the report and/or complaint;
  • Conduct a complaint inspection if allowed entry to the home-based premises;
  • Consult with the CID Manager and/or CID Supervisor and the MOH on findings from the inspection that indicate a health risk to the public from inappropriate infection control practices;
  • Create an outbreak in iPHIS if client contact and follow-up is deemed necessary; and
  • Notify City By-Law if uninspected home-based premises are within the City of Guelph.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Policy CA.82.02.121 Uninspected Tattoo/Piercing or Other Personal Service Premises
Infection Prevention and Control Best Practices for Personal Service Settings
CA.50.01.101 and CA.50.02.101 Documentation Practices
CA.86.01.103 and CA.86.02.103  Notebook Documentation  
CA.86.01.104 and CA.86.02.104 Collecting Photographic Evidence
Infection Prevention and Control Best Practices for Personal Services Settings
Infection Prevention and Control Practices Complaint Protocol
Practices for Cleaning, Disinfection and Sterilization of Medical Equipment Devices in All Health Care Settings

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases

APPROVED BY

Director, Health Protection