No N95? Consider elastomerics, OSHA says

Directive to guide H1N1-related inspections

You might receive a citation from the U.S. Occupational Safety and Health Administration if you fail to assess respiratory hazards related to 2009 H1N1, don't use various methods to reduce employee exposure or fail to consider respirators other than N95s when there is a shortage.

Those are a few of the items included in OSHA's compliance directive, which guides inspectors as they consider potential violations. OSHA is enforcing the Centers for Disease Control and Prevention H1N1 guidance related to protecting health care workers during pandemic H1N1. (Editor's note: The OSHA compliance directive can be found at www.osha.gov/OshDoc/Directive_pdf/CPL_02_02-075.pdf.)

H1N1-related inspections will occur in response to worker complaints, referrals or fatality or catastrophe investigations, OSHA said. Health care workers are considered to have high exposure risk if they are within 6 feet of patients with suspected or confirmed H1N1 (including being in a small patient room with the patient) or if they are transporting those patients in an enclosed vehicle. OSHA considers workers to be at very high exposure risk if they are performing an aerosol-producing procedure — bronchoscopy, sputum induction, endotracheal intubation and extubation, open suctioning of airways, cardiopulmonary resuscitation, or autopsies.

"Since there is a great need for more research on the 2009 H1N1 influenza transmission, workers involved in tasks or activities which place them at high to very high exposure risk must be offered protection from all possible routes of transmission (contact, droplet and airborne) to assure their protection," OSHA stated.

In an inspection, OSHA compliance officers will first look at written pandemic influenza plans and information about worker training. They will conduct a walk-around, interview employees, and review employee medical and exposure records and injury and illness records. If N95 respirators are in short supply, health care workers may wear respirators in extended use (with multiple patients) or may reuse respirators as long as they remain intact and are not visibly soiled, according to both CDC and OSHA.

Yet in a shortage, employers should consider reusable elastomeric or powered air-purifying respirators, OSHA said. OSHA also laid out its expectations to avoid a citation if employees with high-risk exposures aren't wearing N95 respirators or greater:

"[Compliance officers] shall issue a citation for the failure to provide a respirator at least as effective as an N95 respirator to employees providing care in close-contact (within 6 feet) of suspected or confirmed 2009 H1N1 influenza patients, unless the employer can establish all of the following:

• There is a shortage of respirators that are at least as effective as an N95 respirator or better;

• The employer made a good faith effort to obtain other alternative respirators such as N99, N100, or reusable elastomeric respirators;

• The employer made an effort to monitor their supply of N95s and to prioritize their use according to CDC guidance;

• Surgical masks and eye protection devices were provided as an interim measure to protect against splashes and large droplets (Note: surgical masks are NOT respirators and do not provide protection against aerosol-generating procedures);

• Other measures were instituted to protect employees, for example, use of partitions or other engineering controls that might reduce the need for PPE or reducing exposure through cohorting patients."

According to the compliance directive, OSHA inspectors will expect hospitals to use engineering and administrative controls, such as airborne infection isolation rooms, sneeze guards to protect clerical intake workers, policies to limit exposure of unprotected health care workers, and offering vaccination offered free of charge.

OSHA inspectors also may cite employers for failing to "ensure the use" of other personal protective equipment, such as goggles or face shields, or for failing to fully implement a respiratory protection program that includes training and fit-testing.