Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Disease Reporting and Control [12 VAC 5 ‑ 90]
Action Amendment to comply with changes in public health practice
Stage Proposed
Comment Period Ended on 9/11/2015


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7/14/15  11:09 am
Commenter: Donald R. Stern, M.D., M.P.H., Director, Richmond City Health District

Change in definition of EBLL

Elevated Blood Lead Levels:

Does changing the definition of elevated blood lead level from 10 to “the reference value established by the CDC. In 2012, the reference value was 5 μg/dL in children and 10 μg/dL for persons older than 15 years of age” raise community expectations for public health action? Who asked to change the state regulations in these regards? There is no state funding for addressing elevated lead levels, but simply changing the definition of EBLL, has substancially increased the reported elevated lead levels.  Are there any expectations then that local health departments do anything about these elevated lead level test results? By including this new definition, which really is a "concern" level not an "action" level according to the CDC, do we legitizime the expectation that the state take action on these lead levels as well?  Recommend that the definition not change unless there is clear and compelling evidence in the medical literature that a level of 5 may result in harm and that action can be taken to reduce this level or exposure and not base the definition of EBLL on laboratory technical capability to measure blood lead levels that low.

Item C. Rapid Reporting:

Item C requires reportable diseases requiring rapid communication be reported to a local health department in the same locality of the lab, not the patient. This may result in delayed action when the patient and ordering physician/facility is in one part of the state and the lab is in another part of the state. Why not have the lab report to the health department of the patient’s residence or ordering physician or health care facility? I recall a Hepatitis A case in a food service worker that did not get reported to me for 2 weeks though the lab did report to the local health department where the lab was located. These are all relatively rare events and it would not be asking much of the lab since they would already have the location information on the ordering facility and physician at least. They could easily have a list of the associated local/district health department and the EPi # to call. Or give them one number in the central office – an on call number for rapidly reportable diseases and have it dispatched to the local health department from there. Lets step it up, improve the reporting requirements, not just clean up the wording in the regulations.

CommentID: 40535

7/22/15  4:20 pm
Commenter: Bonita Allen BSN RN Infection Preventionist

Suggest clarify SARS in reportable list by adding (i.e. MERS)

Page 2118 and other associated lists: Suggest add (i.e. MERS) to this statement

 *Severe acute respiratory syndrome (SARS), including any coronavirus causing a severe acute illness (i.e.MERS)

Even though this is explained in disucssion on page 2116, the reportable diseases summary list is often the main reference for "reporters".  This clarification could ensure better understanding.  Agree with other changes. 

CommentID: 40545