Pandemic Triggers Respiratory Protection for Healthcare Workers

Back in 2007, OSHA published a document titled “Pandemic Influenza preparedness and Response Guidance for Healthcare Workers and Healthcare Employers” .  This document directly addresses the need for healthcare employers to establish a comprehensive respiratory protection program that includes all of the elements specified in 29 CRF 1910.134.  30 million healthcare workers are now subject to OSHA Respiratory Compliance requirements. Granted, this guidance may not technically carry the weight of a regulatory standard, OSHA may use its enforcement authority under the General Duty Clause, (Section 5(a)(1)) once exposure has been shown.

Regulatory Enforcement

OSHA can do this because the General Duty Clause requires employers to provide their employees with a workplace free from recognized hazards that are likely to cause death or serious physical harm.  Citations may result when there is a recognized hazard and employers fail to take reasonable control actions.  Pandemic influenza is a recognized hazard that will eventually materialize and there are reasonable steps that may be taken to control the spread of the disease. However, steps that are reasonable prior to a pandemic may nearly become insurmountable obstacles during a pandemic.

Preparation is Essential

For instance, according to OSHA and respirator manufacturers, there will be a worldwide shortage of respirators when a pandemic occurs.  Surgical masks are not a substitute for respirators because they are not designed to prevent inhalation of airborne contaminants.  On the other hand, bacteria and viruses are particles and can be filtered by particulate respirators.  OSHA’s Respiratory Protection standard requires the use of a NIOSH (National Institute of Occupational Safety and Health) certified respirators, as well as, the implementation of a comprehensive respiratory protection program.

However, there are three things that must occur before an employee uses a Respirator:

  1. The employee must be medically evaluated and approved to wear a respirator.
  2. The employee must be fit tested to ensure that the respirator is working effectively.
  3. The employee needs to be trained to use the respirator.

If you have any questions or need assistance in how to comply with this list, please contact a Conney Safety expert advisor at 800-462-1947.

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