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OSHA to Issue H1N1 Inspection Standards, Following CDC Guidance

By Roy Maurer  10/20/2009
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A compliance directive on H1N1 flu inspection standards for health care employers is coming soon, the U.S. Occupational Safety and Health Administration announced Oct. 14, 2009.

A statement from Jordan Barab, acting assistant secretary of labor for OSHA, said the upcoming compliance directive “will closely follow” the new Centers for Disease Control and Prevention (CDC) guidance, published Oct. 14. The directive aims to ensure uniform inspection procedures for high and very high risk occupational exposures, such as in health care.

OSHA inspectors will ensure that health care employers implement a hierarchy of controls, including source control, engineering and administrative measures, and encourage vaccination and other work practices recommended by the CDC. Where respirators are required to be used, the OSHA Respiratory Protection standard will be enforced, including worker training and fit testing, according to the agency statement.

“Employers should do everything possible to protect their employees,” Barab said. He emphasized, however, that where respirators are not commercially available, an employer will be considered to be in compliance if the employer can show that a “good faith effort” has been made to acquire respirators.

For health care personnel who are in close contact (within six feet) with patients with suspected or confirmed H1N1 influenza, the CDC recommends the use of respiratory protection that is at least as protective as a fit-tested disposable N95 respirator. Since a shortage of disposable N95 respirators is possible, employers are advised to monitor their supply, prioritize their use of disposable N95 respirators, and to consider the use of elastomeric respirators and facemasks if severe shortages occur. In addition, an employer must prioritize use of respirators to ensure that sufficient respirators are available for providing close-contact care for patients with aerosol-transmitted diseases such as tuberculosis.

Where OSHA inspectors determine that a facility has not violated any OSHA requirements but that additional measures could enhance the protection of employees, OSHA may provide the employer with a Hazard Alert Letter outlining suggested measures to further protect workers, according to the statement.

CDC Updates H1N1 Guidance

Updated CDC guidelines for protecting health care workers from the H1N1 (swine) flu emphasize a hierarchy of infection controls and a recommendation for N95 respirators for those in close contact with suspected or confirmed infected patients, but with additional recommendations addressing anticipated shortages.

The CDC’s Interim Guidance on Infection Control Measures for 2009 H1N1 Influenza in Healthcare Settings, Including Protection of Healthcare Personnel lists personal protective equipment as the lowest level of control, behind eliminating potential flu exposures, engineering controls and administrative controls.

Eliminating the potential source of exposure ranks highest in the CDC’s hierarchy of controls: take steps to minimize outpatient visits for patients with mild influenza-like illness who do not have risk factors for complications, postpone elective visits by patients with suspected or confirmed influenza until they are no longer infectious, and deny entry to visitors who are sick.

Engineering controls are particularly effective because they reduce or eliminate exposures at the source, and many can be implemented without placing primary responsibility of implementation on individual employees, and protect patients as well as personnel. An example of engineering control includes installing partitions in triage areas and other public spaces, to reduce exposures by shielding personnel and other patients.

Examples of administrative controls include promoting and providing vaccination; enforcing exclusion of ill health care personnel; implementing respiratory hygiene/cough etiquette strategies; setting up triage stations and separate areas for patients who visit emergency departments with influenza-like illness; managing patient flow; and assigning dedicated staff to minimize the number of health care personnel exposed to those with suspected or confirmed influenza.

Personal protective equipment ranks lowest in the hierarchy of controls. It is “a last line of defense for individuals against hazards that cannot otherwise be eliminated or controlled,” according to the guidance.

Shortage of Respirators

Most authorities have recommended that health workers who are in direct contact with H1N1 patients wear N95 respirators to ensure they are protected. Surgical masks are not fit-tested and are not considered adequate protection against the virus. (See “OSHA’s Respiratory Infection Control: Respirators Versus Surgical Masks.”) Some health care centers are already feeling the effects of shortages in respiratory protection equipment because of a large gap between supply and demand that is predicted to continue, the CDC said. In these cases, it recommends that health care professionals wear the surgical masks instead if N95 respirators are unavailable. In addition, where supply shortages exist, facilities should allow employees to extend the use of disposable N95 respirators by wearing them during multiple patient encounters as well as reusing them even when they are removed between patients.

“Although these practices have the potential benefit of providing respiratory protection with limited supplies of respirators, there is the risk of respirator contamination and contact transmission,” the CDC said.

Roy Maurer is a staff writer for SHRM.


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