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OSHA has released its enforcement policy for occupational exposure to H1N1 influenza in healthcare facilities or labs.

11/20/2009

The directive establishes uniform procedures for inspections to identify and minimize or eliminate high risk occupational exposures to the H1N1 influenza virus.

In response to complaints, OSHA inspectors will ensure that health care employers implement a hierarchy of controls, and encourage vaccination and other work practices recommended by the CDC. Where respirators are required to be used, the OSHA Respiratory Protection standard must be followed, including worker training and fit testing. The directive also applies to institutional settings where some workers may have similar exposures, such as schools and correctional facilities.

OSHA's compliance document closely follows the CDC's October 14 guidance document for infection control in healthcare facilities, which says healthcare workers potentially exposed to H1N1 influenza should wear PPE including respiratory protection that is at least as protective as a fit-tested disposable N95.  Under the guidance, respirator use is part of a recommended program that includes vaccination of healthcare workers (HCWs), respiratory hygiene and cough etiquette, and facility control and triage measures to reduce HCW exposure to infected patients. Where exposure cannot be controlled, CDC makes specific recommendations for isolation precautions for all HCWs working within 6 feet of a patient, or entering a small enclosed airspace shared with the patient, such as a patient room. These precautions include wearing nonsterile gloves for any contact with potentially hazardous material, and gowns and eye protection for any activity that might generate splash of respiratory secretions or other infectuous material.

Respiratory protection should be at least as protective as a fit-tested disposable N95 respirator. CDC points out that this recommendation is specific to the 2009 H1N1 pandemic, and may be revised as new information becomes available. If a facility experiences shortages of N95s, it should use source control, engineering and administrative practices to reduce the number of HCWs who come into contact with patients who have influenza-like illness. CDC explicitly notes that facilities should consider more protective filtering facepiece respirators, elastomeric respirators or PAPRs if they are experienced in their use. Facilities must ensure that they have enough respirators to be able perform aerosol-generating procedures throughout the anticipated flu season, as well as care for patients with other infections such as TB.

If shortages persist despite a facility's good faith efforts to maintain supply, CDC recommends prioritizing use so that respirators are available to the most at-risk HCWs and those performing aerosol-generating procedures. HCWs who cannot get respirators because of prioritized use may be provided with FDA-cleared facemasks.  Details on how a facility can conserve respirators for critical use are included in a Q&A document released by CDC.

OSHA will expect employers to use good-faith efforts to obtain respirators, including alternative respirators such as N99, N100 or elastomerics.  OSHA notes that it requires that all respirators be NIOSH certified, but does not require FDA clearance.