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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.

pages-from-osha_pandemic_health-cover-border [1]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, [1] 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 [2] 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:

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?