New OSHA Directive: Tread Carefully with Respirator Shortages

In releasing a new compliance document for inspectors visiting healthcare facilities treating H1N1 patients, the Occupational Safety and Health Administration (OSHA) makes two primary statements:

• Hospitals must follow the Centers for Disease Control and Prevention's (CDC) guidelines on protecting healthcare workers from H1N1 exposures


• There must be a good-faith effort to provide workers with N95 respirators, and if there is a legitimate shortage of these respirators, there should be evidence of ongoing monitoring of N95 supplies

 

OSHA's compliance directive, which the agency posted online Friday, outlines various deficiencies of H1N1 protection that could result in citations for hospitals.

H1N1 inspections will follow the traditional procedures of any OSHA visit, with an opening conference, document reviews, and tours of affected areas. It is unusual, though, to see OSHA issue a directive so squarely aimed at healthcare facility compliance.

"OSHA has a responsibility to ensure that the more than 9 million frontline healthcare workers in the United States are protected to the extent possible against exposure to the virus," acting Assistant Secretary of Labor for OSHA Jordan Barab said in a statement. "OSHA will ensure healthcare employers use proper controls to protect all workers, particularly those who are at high or very high risk of exposure."

OSHA classifies those two levels as follows:

• Very high exposure risk—Generally, healthcare workers performing aerosol-generating procedures (e.g., bronchoscopies) on suspected or confirmed H1N1 patients or healthcare workers present during autopsies


• High exposure risk—Generally, healthcare workers working within 6 feet of suspected or confirmed H1N1 patients or entering a small room shared with such a patient

 

What to expect during an OSHA visit
OSHA will conduct H1N1 inspections in response to worker complaints, referrals (including from media reports), and related employee fatality investigations. Remember, OSHA is strictly interested in worker well-being, not patient safety.

During H1N1 inspections, OSHA representatives will meet with infection control and safety managers, review information about the hospital's exposure risk assessments, evaluate pandemic flu plans, and scrutinize worker training programs related to H1N1 protection.

Citations related to worker exposure to H1N1 can fall under a variety of OSHA standards, including requirements to report occupational illnesses, ensure workers wear personal protective equipment, and provide proper respiratory protection for employees.