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Fast-track guide to H1N1 OSHA compliance

The H1N1 Preparedness–Lessons Learned & Successful Strategies webinar [1] 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 [2]recommendations and OSHA [3] 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:

Engineering controls

Administrative controls

Personal protective equipment

Prioritize your facilities use of N95 respirators


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.