Healthcare Respirator Programs During (and After) Covid

February 28, 2021
For many healthcare employers, the Covid-19 pandemic was the beginning of a workplace respirator program. Most did not have a respirator program prior to the pandemic, and are looking forward to returning to that, but aren't sure how to make that decision moving into 2021. 

Without a fairly detailed dive into the specific of your workplace, existing safety policies, types of procedures performed, patient screening methods used, regulations specific to your healthcare sector, and a variety of other risk factors, we cannot advise on a specific course of action. For employers looking for professional guidance of this type, we offer consulting services and can provide a proposal. 

For healthcare employers making this determination themselves, they should carefully review Cal/OSHA's Aerosol Transmissible Diseases regulation, California Department of Public Health requirements, and any local City/County guidelines, and consider the following:

Will employees be seeing confirmed or suspected Covid-19 patients?
If you are, for example, a medical clinic that will be seeing patients with respiratory or flu symptoms for evaluation and diagnosis, or you are a dental office that will have to provide emergency care for patients who have Covid 19, Cal/OSHA's aerosol transmissible diseases standard requires a full respirator program (with fit testing and training renewed annually).

If you are not seeing confirmed or suspected Covid-19 patients, conduct screening of all patients (recognizing fully the limitations of symptom and history based screening methods that will not detect asymptomatic and presymptomatic individuals), outpatient medical and dental offices have greater leeway in determining whether to continue with a respirator program.

One important point is the nature of healthcare often requires providing urgent or emergency care to patients who may either have Covid-19, or have other fairly common upper respiratory symptoms that would meet the criteria for potential Covid-19 infection. 

Will employees be required to wear a respirator? Remember: an "N95 mask" is a respirator. 
Regardless of risk, if employees are required to wear a respirator for any work tasks, you must implement a full respirator program (with fit testing and training renewed annually). 

Are there other regulations or third party standards requiring a respirator program?
Even though you may not be required to maintain a respirator program by Cal/OSHA requirements, there may be public health requirements specific to your industry that require it. Or, third party organizations may require it as part of their accreditation standards. 

How has the availability of vaccination changed risk factors in the workplace?
There is always a benefit from decreased community transmission, but the impact on vaccination programs in your specific organization depends on a variety of factors, including the willingness of your workers to take the vaccine (and, related, your company policy on requiring them as a condition of employment). Significant ambiguity still exists regarding the duration of protection offered by the vaccine, and its effectiveness against emerging variants of Covid-19.

Is a respirator program needed for other pathogens? 
Many employers have discovered that even with a decreasing threat from Covid-19, they still have a need for a respirator program (and in fact, should have had one all along). Particularly within medical clinics and hospitals, there may be a need to protect certain classes of employees from pathogens like tuberculosis. Dental professional may have to provide emergency care to a patient who also has a respiratory illness, and need a higher level of protection than would be provided by a procedure mask. 

How effective are other safety controls used in the workplace?
Personal protective equipment like a respirator should be used when there are not other ways to effectively manage a hazard. Safer work practices and engineering controls, like isolation shielding or air purifiers, should be the first line of defense.  The more effective these methods are, the less need there is for a respirator. Unfortunately, quantifying the effectiveness of controls against biological contaminants is not as easy as it is for chemical contaminants (where a variety of well-established methods exist to measure airborne concentrations)...so there's a fair amount of research and more qualitative professional judgement required here. A lack of effective safety controls, or ambiguity about their effectiveness means a respirator program should be maintained. 

Would a respirator program, even if not required, improve workplace conditions?
Just as they did in early 2020, many employers deciding they will continue to maintain a respirator program through 2021 for all clinical staff, to keep everyone as safe as possible, which paid dividends in terms of morale, employee retention, and job satisfaction in the midst of the pandemic. There are also benefits in terms of reduced workforce disruption (less need to quarantine employees with potential exposure if they are wearing appropriate protective equipment). 
By carlo January 27, 2025
HAZWOPER (Hazardous Waste Operations and Emergency Response) training requirements apply to certain operations involving hazardous waste. These requirements dictate the amount, type and levels of training that employees working with hazardous waste must receive. The requirements for hazwoper training can be found in Cal/OSHA § 5192 and Federal 49 CFR 1910.120 . In general, there are three categories of hazmat operations, and specific training requirements for each. These three categories are hazmat site cleanup, emergency response, and operations at treatment, storage, and disposal facilities. Site Cleanup Cleanup and removal work at sites that have been identified by a government agency (state, federal, or local) as having an accumulation of hazardous substances that creates a threat to the health and safety of individuals or the environment or both. General site workers removing hazmat with potential exposure to hazardous substances and health hazards shall have 40 Hours of Training + 3 Days Supervised Field Experience. General site workers in areas where hazard levels have been fully identified, exposures are below published safety limits, there are no health hazards, no possibility of an emergency release, and respirators are not required shall have 24 hours of training + 1 day supervised field experience. Occasional/limited site workers (such as those doing monitoring or surveying) and are unlikely to be exposed to dangerous levels of hazmat shall have 24 hours of training + 1 day supervised field experience. Supervisors of general site workers shall meet the same training requirements as that category of general site worker, plus have an additional eight additional hours of specialized hazardous waste operations management training. All categories of site cleanup workers shall have 8 hours of annual refresher training. Emergency Response Emergency response to releases of, or substantial threats of releases of, hazardous substances, regardless of location. Awareness Level (FRA): Basic awareness, recognize hazmat threat, call for help. Competence based, no hourly requirement. Operations Level (FRO): Defensive response, contain and limit the release. Competence based, or 8 hours of training required. Hazmat Technicians and Hazmat Specialists: Direct response to stop a release of hazardous substances. Training scope and duties varies depending on position/role. 24 hours of training required. Incident Commander/Manager: Control and manage scene, implement response plans. 24 hours of training required. All emergency response workers shall receive annual refresher training or evaluation to demonstrate competency in their required areas. TSDF Operations Operations at Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs) Workers are required to have 24 hours of initial training, and 8 hours annual refresher training.
By carlo December 28, 2024
The most important thing to know about snakebites is that people drastically overestimate both the likelihood and the severity of venomous snake bites in the US. Snakebites are fairly rare, and fatalities from snakebites are so unlikely (generally 5-10 per year in the entire country), a person is many times more likely to die from a lightning strike, or a heat-related emergency, or any number of other outdoor hazards. Prevention is simple. It is relatively simple to avoid most snakebites by being aware of where you step, not reaching or climbing on any area you haven't visually inspected first, and not approaching snakes to catch, kill, or photograph them. There are some significant misunderstandings about first aid measures for snake bites, many unfortunately perpetuated by uninformed first aid instructors and irresponsible equipment vendors. Do NOT apply suction. Avoid the use of commercial snakebite kits with suction pumps, like the Sawyer Extractor. See our article on venom extractors for more information on these ineffective and dangerous devices. Do NOT apply tourniquets or constricting bands. Do NOT cut the skin. Basic first aid measures are simple. Here's what you should do: Keep the person calm and avoid unnecessary movement. Why: Keeping the person's heartrate in a normal range slows the distribution of venom in their body. Remove watches, rings, and other tight fitting items. Why: These can constrict bloodflow if the person's limbs start to swell due to the venom. Call 911. If you do not have cellphone service, you will have to consider either finding a way to transport the person, or leaving them while you try to reach an area with cellphone service. Why: The only definitive care for a venomous snakebite is transport to a hospital for supportive care, and possibly anti-venom medication. For people working (or recreating) outdoors, mindfulness of where you place your feet and hands is your best defense against snakebites. If you will be in an area without cellphone coverage, investing in a means of emergency communication such as a satellite phone or messenger, personal locator beacon, two-way radio is the most important part of your emergency response plan. Three action steps for California employers: Review this information with your workers in April or March, which is when snake sightings will begin to increase. Ensure workplace first aid supplies do not contain outdated and dangerous supplies like snakebite kits and venom extractors. Ensure workers in remote areas have adequate means of emergency communications.
By carlo December 28, 2024
Cal/OSHA's requirements for workplace respiratory protection can be found in Section 5144 of the California Code of Regulations. Any employer with tasks requiring employee respirator use needs to comply with these requirements, and employees must be medically approved, trained, and fit tested prior to using a respirator at work. Remember, you can't adequately protect employees unless you know what to protect them against, and how serious the potential exposure is. For this reason, a hazard assessment should be the first step before starting a respiratory protection program. You should determine what sort of respiratory hazards exist in the workplace. You have to consider the types and concentration of contaminants employees they might be exposed to. Always start by seeing if you can eliminate the need for respirator use by controlling the hazard some other way. If not, then your next step is to develop an appropriate workplace respirator program. This short guide explains the basics of respirator use in the workplace; always refer to the full OSHA standard when developing your program. Administrative Program Why: Without a formal plan, you cannot effectively implement and run a safety program. A written respiratory protection program identifies respiratory hazards, and details the steps you are taking to reduce these hazards, including employee respirator use. This program must be customized to your location. Your written program should summarize the results of your hazard assessment, and how respirators will be used in your workplace to keep employees safe. It should specify which positions or tasks require respirator use, what types of NIOSH-approved respirators are to be used, and how your company will provide required medical evaluations, fit testing and training for your employees. The program should also describe procedures for respirator use and maintenance, ongoing program evaluation, and who is in charge of overseeing the respirator program. Cal/OSHA §5144(c): "The employer shall ... develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator." Cal/OSHA §5144(f): "The employer shall ... provide for the cleaning and disinfecting, storage, inspection, and repair of respirators used by employees." Cal/OSHA §5144(g): "The employer shall ... establish and implement procedures for the proper use of respirators..." Medical Evaluation Why: Respirator use puts greater stress on the worker's body, especially the heart and lungs. A medical evaluation helps rule out any serious health problems that could be worsened by respirator use. Before wearing a respirator at work, employees are required to complete a health history questionnaire, which should be evaluated by a healthcare provider, who will give their approval for that employee to wear a respirator. Most employees will be approved right away, while others may need to provide additional information to the healthcare provider, have a more detailed evaluation, or have limitations on respirator use. Some companies will also require employees to have a physical evaluation, or a pulmonary function test. The medical evaluation should be renewed according to the recommendation of the healthcare provider issuing the approval (usually annually), or sooner if the employee has any health changes or problems that could affect their safe use of the respirator. Cal/OSHA §5144(e): "The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace." Employee Training Why: Workers need to know how the respirator works, how to use it correctly in the workplace and problems to watch out for. Employees should receive training on the capabilities and the limitations of the respirator, what tasks they should use the respirator for, how to inspect, put on, remove, and use the mask, procedures for maintenance (if applicable) and storage, recognition of the medical signs and the symptoms that may limit or prevent an employee’s effective use of a respirator, and the general requirements of the OSHA standard. Training should be renewed at least annually, or sooner if there are significant changes to the type of work being done, or the style of respirator used by the employee. Cal/OSHA §5144(k): "The employer shall ... provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary." Fit Testing Why: Every person's body is different, and employees need to make sure they are wearing a respirator that makes an adequate seal to their face. Employees should be fit tested to identify the specific make, model, style, and size of the respirator that is best suited for each employee, and check for problems with respirator condition, use, and donning procedure. There are different fit test methods required depending on the mask type and workplace contaminants. Fit testing should be renewed at least annually, or sooner if the employee has physical changes that could affect respirator fit, or experiences issues with the fit of their issued respirator. Cal/OSHA §5144(f): "...before an employee may be required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style, and size of respirator that will be used." Together, the administrative program, medical evaluations, employee training, and fit testing form the core of an OSHA-compliant workplace respirator program. Safewest can assist employers with all required elements of a respiratory protection program. If you need help, or just want a few questions answered, contact us for a free consultation.
By carlo October 31, 2024
OSHA’s respiratory protection standard leaves no ambiguity: tight-fitting respirators cannot be used with facial hair in the seal area of the facepiece. Non-compliance remains common, creating unnecessary risk to employee health, and exposing employers to OSHA penalties for worker noncompliance. What follows is a summary of the relevant regulations and guidance:
Show More