Fast-track guide to H1N1 OSHA compliance

By: October 29th, 2009 Email This Post Print This Post

The H1N1 Preparedness–Lessons Learned & Successful Strategies webinar presented by Premier, Inc. on October 28 excellently distilled CDC and OSHA compliance issues for protecting workers from H1N1.

The key is to customize your policy while staying within CDC recommendations and OSHA regulations. Sure that takes more time and effort, but it gives you more flexibility, for compliance.

I have found that so much angst about not having N95 respirators and not being able to fit test and train employees to use them is because healthcare facilities have jumped to the personal protective equipment (PPE) option without working through the hierarchy of controls and prioritization of PPE.

Here are some key hierarchy, prioritization, and documentation steps from CDC and OSHA sources as presented in the webinar:

Work through the hierarchy of controls for infection control (notice that respirators and PPE are at the bottom of the list)

Eliminate source of infection:

  • Postpone elective visits, procedures if influenza-like illness (ILI)
  • Deny entry to ill visitors, keep ill personnel at home

Engineering controls

  • Aerosol generating procedures (use airborne infection isolation room)
  • Physical barriers/partitions in triage areas
  • Soap dispensers, trash containers

Administrative controls

  • Vaccination
  • Screening and enforcing exclusion of ill staff and visitors
  • Education, patients and visitors – cough etiquette, hand hygiene, masks if needed

Personal protective equipment

  • Gloves, gown, facemasks, respirators (N95), eye protection, as appropriate
  • Use of fit-tested N95s when in close patient contact (within 6 feet)
  • Options when supplies are short

Prioritize your facilities use of N95 respirators

  • Use N95 or higher level of protection (e.g. Powered Air Purifying Respirator-PAPR) for high risk procedures like those that generate aerosols, such as bronchoscopy
  • If NOT doing a high risk procedure, prioritize use of either N95 or surgical mask based on:
    –Vaccination status of worker
    –If worker is in a high risk group for complications, (e.g. pregnant)
    –Frequency of close exposure procedures and contact
  • Consider extending use of disposable N95 respirators in special situations for multiple patient encounters (during triage)


  • OSHA will enforce worker protection components of CDC interim guidance so be sure to document hierarchy of controls
  • Show and document “good faith” effort to provide respiratory protection that is at least as effective as N95 respirators
  • Document prioritization plan for respiratory protection including consideration of:
    –Vaccination status of workers
    –Type of procedure (routine care vs. aerosol generating)
    –Frequency of close exposure (within 6 feet)
    –Risk factor of complications (pregnant workers)
    –Document respirator shortage/evidence of attempt to buy

Several sources in the webinar indicated that when the OSHA H1N1 enforcement directive does come out it will favor flexibility and reward those facilities that have taken steps to customize their plans to site-specific hazards and procedures and the requirements of local and state departments of health.


By Kevin Wiley on October 30th, 2009 at 12:31 pm

In the part covering PPE, are they saying that you only need to fit test the respirator IF they will be used within 6 ft close contact?

By David LaHoda on October 30th, 2009 at 4:09 pm

Thanks, Kevin, for pointing out that potential confusion, and I reworded the bullet to read: “Use of fit-tested N95s when in close patient contact (within 6 feet)”

OSHA has not changed the requirement under the respiratory protection standard that requires fit-testing for face piece respirators such as N95s.

Take a look at the link. Any chance for an impact?

IDSA: N95 vs Surgical Mask Findings Retracted

PHILADELPHIA — In a surprise twist, authors here retracted findings of a study that found N95 respirators were better than surgical masks at preventing flu. After a re-analysis prompted by questions from reviewers, the findings were no longer… full story

Editor’s note: the first link was incorrect. Here is the the good link


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