Scrambling for a respiratory protection plan
This week’s focus on swine flu has jolted a number of healthcare facilities to reconsider whether they need a respiratory protection plan for their employees. I know, because I’m receiving the phone calls to prove it.
As one caller put it: “If I can get enough N95 respirators to protect my employees, what do I need to do to have my employees wear them?
A little bit of time and planning, for one thing, but that seems to be in short supply right now.
Who knows what regulators will overlook in the throes of struggling to cope with a pandemic, but here is what OSHA said in its 2007 Pandemic Influenza Guidance for Healthcare Workers and Healthcare Employers, about what employers must have as elements of a compliant respiratory protection plan.
The OSHA respiratory protection standard (29 CFR 1910.134) requires employers to establish and maintain a written respiratory protection program to protect their respirator-wearing employees. Elements of the program must include the following:
1. Program administrator. Experience is appropriate if it enables the program administrator to recognize, evaluate, and control the hazards in the workplace.
2. Respirator selection. Selection of appropriate respirators requires an understanding of the airborne infectious agents, the operating characteristics of the respirator, and the behaviors of the healthcare workers using it. Respirators for protection from pandemic influenza must provide, at the minimum, an N95 protection value and be certified by NIOSH.
3. Medical evaluations. Employers must evaluate whether employees are able to wear respirators. Evaluation can be performed by questionnaire or medical examination.
4. Fit testing. The standard requires employers to conduct fit testing initially and annually on all employees required to wear respirators with tight-fitting facepieces. Testing takes approximately 30 minutes per employee.
5. User seal checks. Tight-fitting respirators with leaks in the seals or valves cannot reduce the wearer’s exposures to respiratory hazards. Conditions that can interfere with seals or valves include facial hair, facial scars, jewelry or headgear, missing dentures, corrective glasses or goggles, or other personal protective equipment. Every time an employee puts on a respirator, he or she must conduct a user seal check.
6. Maintenance and care of respirators. Employers must provide respirators that are clean, sanitary, and in good working order to ensure that equipment protects as designed.
7. Cleaning and disinfection. Reusable equipment must be regularly cleaned and disinfected according to specified procedures of the standard or manufacturer specifications that are of equivalent effectiveness.
8. Storage of respirators. Employers must store respirators in a manner that protects them from contamination and prevents facepiece or valve deformation.
9. Training and information. Before requiring respirator use during work, employers must provide training on:
- Respirator necessity and how improper fit, usage, and maintenance can make it ineffective
- The limitations and capabilities of the selected respirator
- How to inspect, put on and remove, and check the seals of the respirator
- The proper respirator maintenance and storage procedures
- The general requirements of the respiratory protection standard
Employers must retrain employees annually and whenever there are changes in workplace conditions or respirator selection, or whenever there is evidence of improper respirator use.
Are you hustling to get a respiratory protection plan up and running now, or did you heed the advice of OSHA and the CDC years ago and plan ahead?
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David LaHoda
David LaHoda, the managing editor of Medical Environment Update and OSHA Watch, has produced healthcare training videos and consulted for medical practices and ambulatory healthcare facilities.
David has written 196 posts.
Comments
We are currently seeing a number of our clients evaluating whether or not they need to have medical clearance provided for their EE’s to wear N95’s. We are in agreement with this article that they should have employees cleared and fit tested in advance…even to wear an N95. I get the impression that many organizations are waiting for some “trigger” (a confirmed H1N1 case in their employee population, elevation of the Pandemic threat level to 6, etc.) before they move forward. That could prove to be unfortunate. Now is the time to prepare.
Adam H. Underwood
Director of Business Development
The EI Group, Inc.
http://www.ei1.com
Direct: 919 . 459 . 5264
Mobile: 919 . 621 . 0945
We have been very active at our facility doing fit testing along with training staff to assist with this process. The program administer and occupational health staff are still responsible for medical clearance. This is our issue…when we received the strategic national stockpile (SNS)there were 3 different N-95 particulate respirators in the stock. None of these respirators are the type we currently fit for. Under OSHA guidelines we would need to fit staff for each type of these respirators if we choose to use them due to supply issues. Are there other facilites dealing with this? How are they dealing with this issue? Thank you
We are dealing with the same supply issue. Small 3M respirators are running low. The respirators are on a back order, and have been since May. We have around 7,000 employees. Now we will have to refit each employee in a different brand. What will happen in the fall when all respirators will be on back order?
I work in long term care and we have a supply of the 3M respirators on hand and want to start the fit testing process-are you aware or can you provide samples of a medical clearance documentation tool. We want to be sure we screen for all the known potential risk factors in our employees. Thank you
Click here for the OSHA Respirator Medical Evaluation Questionnaire. It is Appendix C to the respiratory protection standard, 1910.134.
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