What OSHA inspectors will ask about H1N1

Be OSHA-ready with the answers

The Occupational Safety and Health Administration's compliance directive to protect health care workers from H1N1 pandemic influenza A includes a series of questions inspectors may ask when on a health care site visit. Know the answers to these and you're OSHA ready in terms of H1N1:

Planning

  • Has the employer conducted a risk assessment to determine employees' exposure risk to 2009 H1N1 influenza?
  • Has a plan been created using the information gathered in the risk assessment?
  • Is there a person responsible for maintenance of the program and training of employees on the program?
  • Has the employer developed procedures for early identification/isolation of cases (i.e., methods for screening suspected pandemic patients and sick employees)?
  • Does the employer have a policy for dealing with sick workers (i.e., encouraging sick workers to stay at home)?
  • Does the employer have a schedule for cleaning or decontaminating workplaces?

Engineering controls

  • Does the employer perform very high risk aerosol-generating procedures on suspected or confirmed 2009 H1N1 influenza patients?
  • Does the facility have functioning airborne infection isolation room(s) (AIIR)? If so, is it operable?
  • Has the employer implemented other measures for isolating employees from 2009 H1N1 influenza cases (e.g., installation of sneeze guards, windows at clerical intake areas and other barriers between workers and the general public)?
  • Has the employer provided no-touch waste containers for used tissues?

Administrative controls

  • Does the employer provide and promote vaccination and if indicated post-exposure prophylaxis?
  • Does the employer use a separate room(s) to isolate a person suspected to have 2009 H1N1 influenza; does the room(s) contain its own hand-washing sink, toilet, and bath facilities, when possible?
  • Has the employer implemented communication measures to educate patients, employees and visitors (e.g., posting signs at entry points instructing patients, staff and visitors of the policies and of symptoms of influenza)?
  • Are surgical masks used on suspected or confirmed 2009 H1N1 influenza patients who can tolerate use?

Personal protective equipment, including respirators

  • Has a hazard assessment determined the need for personal protective equipment (PPE)?
  • Has the PPE been provided (e.g., eye protection, surgical masks, respirators)?
  • Is PPE available in different sizes?
  • Have employees been trained on the proper use of PPE?
  • Does the employer ensure the use of PPE?
  • Are respirators provided to employees who are entering the rooms of, or in close contact with (e.g., within 6 feet) individuals with suspected or confirmed 2009 H1N1 influenza patients?
  • Are respirators provided to employees who perform aerosol-generating high-risk procedures on suspected or confirmed 2009 H1N1 influenza cases?
  • If respirators are provided, is there a respiratory program in place and has it been reviewed and updated to include 2009 H1N1 influenza risks/exposures?
  • Are employees fit-tested on the respirators they use?
  • If surgical masks are used, what are the circumstances of use (e.g., what is the exposure risk category for employees using surgical masks; what engineering, administrative, or work practice controls have been put in place to supplement the use of surgical masks)?
  • Are there policies in place to keep respirators (or other PPE) clean and well maintained?
  • If there is a respirator shortage, what policies are being used to address protection of employees (e.g., consider additional engineering controls; measures to limit contact; use of surgical masks on patients who can tolerate use; other administrative controls)?

Training

  • What guidance is being given to workers covered under this directive who transport individuals who may be ill or exhibit influenza-like symptoms?
  • Are employees aware of the signs and symptoms of 2009 H1N1 influenza?
  • Are employees familiar with the employer's H1N1 program?
  • Are employees aware of the PPE available?
  • Do employees know what to do if they suspect someone may have 2009 H1N1 influenza and who to report suspected cases to in the facility?
  • Do they know how to protect themselves from contracting 2009 H1N1 influenza and what to do if they have symptoms during the scheduled work time?
  • Do employees know what the facility's policies are for sick employees (e.g., staying at home)?