frequency contact with the general population include schools; workplaces with
high population density, such as banks;
and some high-volume retail stores, such
as grocery stores.
Low exposure risk: a job task or activity
that does not require frequent close contact (within 6 feet) with coworkers or the
general public. Office workers are an example of employees who have minimal
occupational contact with others.
Compliance Issues
The CDC guidelines for H1N1 for health-care workers, finalized in October 2009,
present a new enforcement challenge for
OSHA. Determining what regulators may
be willing to overlook in the face of a
pandemic is impossible, but the OSHA
respiratory protection standard ( 29 CFR
1910.134) specifies what employers must
do to establish a compliant program.
Since H1N1 is transmitted via direct
or indirect person-to-person contact of
infectious droplets when influenza patients
cough, sneeze, talk or even breathe, the
use of respiratory protection for health-care workers is a complex but timely
topic. As good industrial hygiene would
dictate, the CDC guidelines focus on the
importance of source control, engineering
and administrative measures to reduce
the numbers of workers who come into
contact with patients who have flu-like
illness. Personal protective equipment
(PPE) ranks lowest in this hierarchy
because its effectiveness depends on a
number of factors, including training and
continuous use during all potential exposure periods. Failure to comply with
proper use requirements or to recognize
infected patients in a timely manner will
severely limit the effectiveness of PPE. If
respiratory protection is used, the CDC
calls for respiratory protection at least as
protective as a fit-tested, disposable N95
respirator.
Therein lies the challenge for health
care administrators. The CDC and
OSHA’s hierarchy of controls is intended
to extend the use of, or reduce the consumption of, what is likely the most
sought after control mechanism other
than vaccination—the N95 filtering face-piece respirator. As distributors seek to
fill all the orders for disposable respirators and fit-testing kits, many organizations may find themselves left out in
their attempt to comply. SavaSeniorCare,
affiliated nursing facilities with locations
across the United States, decided not to
contend with the possible shortage of
N95 respirators and instead chose to
secure sufficient supplies to protect their
employees and residents from exposure.
“We take seriously the health and safety
of our residents and employees,” said
Nan Impink, senior vice president and
chief operations counsel for SavaSenior-
Care. “Therefore, we decided to be proac-
tive this year and assure that we were
prepared for an H1N1 and/or seasonal
influenza outbreak. Our customers expect
that we will do what is needed to protect
their loved ones.”
CDC details prioritization levels of
respirator protection during respirator
shortages. (The agency does not define
“respirator shortage.”) High-priority
workers include health-care personnel
attending aerosol-generating procedures,
which carry a very high exposure risk,
and those who manage patients with
other diseases that require respiratory
protection (e.g., tuberculosis).
Where respirators are not commercially
available, OSHA will consider employers
to be in compliance if they can demon-
strate that they made a good-faith effort
to acquire respirators. CDC adds that facil-
ities should “maintain a reserve sufficient
to meet the estimated needs for perform-
ing aerosol generating procedures and
for managing patients with diseases
other than influenza that require respira-
tory protection until supplies are expected
to be replenished.”
According to Chris Milby of Orr Safety,
a safety and equipment supplier head-
quartered in Louisville, Ky., “Although
many suppliers have had to place their
supply on allocation, there has not been
any disruption to the supply chain.
There are only issues with trying to
purchase exceptionally large quantities
requiring quick delivery. Many suppliers
have increased their production and
other suppliers have added N95 to the
product lines they carry.”
Alternatives to N95 respirators include
the use of more protective filtering face-
piece respirators, such as elastomeric and
reusable powered air-purifying respirators
(PAPRs). Other filtering face-piece classi-
fications—N, P, R 99 and 100 designa-
tions—are as good as, if not better than,
