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The Occupational Safety and Health Administration, U.S. Department of Labor has published OSHA 3328-05, 2007 Pandemic Influenza Preparedness and Response Guidance for Healthcare Workers and Healthcare Employers. Among other things the Guidance directly addresses the need for healthcare employers to establish a comprehensive respiratory protection program that includes all of the elements specified in 29CFR 1910.134. Although, the Guidance does not technically carry the weight of a regulatory standard, OSHA may use its enforcement authority under the General Duty Clause, (Section 5(a) (1) since a pandemic has been declared. 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 employers fail to take reasonable control actions. H1N1 is a recognized hazard that has risen to pandemic level and there are reasonable steps that may be taken to control the spread of the disease and protect health care workers. However, steps that were reasonable prior to a pandemic may become nearly insurmountable obstacles during the peak of a pandemic and prevent compliance with the OSHA regulation. All health care workers that are in close contact with patients (within 6 feet or who enter a patient's room) are covered by the CDC and OSHA recommendations. OSHA goes on to say that health care employers better be prepared to comply with the regulations. 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 such as N 95's. OSHA's Respiratory Protection standard, 1910.134, requires the use of a NIOSH (National Institute for Occupational Safety and Health) certified respirator, as well as, the implementation of a comprehensive respiratory protection program. However, there are three things that must occur before a health care worker uses a respirator. Employees must be medically evaluated and approved to wear a respirator. Medical evaluations can be performed by using a medical questionnaire (1910.134, Appendix C) or by performing an initial medical evaluation that obtains the same information as the medical questionnaire. The evaluation may be completed electronically through an online medical evaluation service. The evaluation must be conducted during normal working hours or at a time that is convenient to the employee and employers are responsible for paying for the service. 2. The employee must be fit tested to ensure that the respirator is working effectively. 3. The employee must be trained to use the respirator. By: Ronald R. McHaney, CSP The availability of online medical evaluations for respirator users and online training may help expedite compliance with the requirements 1910.134 for health care employers that have fallen behind in their preparation to comply with the OSHA regulation.
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