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My hospital received a notice of complaint from the Division of Occupational Safety and Health alleging that my hospital is violating the Cal/OSHA Aerosol Transmissible Disease Standard due to my respirator conservation strategies. What are my options for respirator use and conservation given the continuing shortage?
On Aug. 6, Cal/OSHA released updated guidance on COVID-19 for Health Care Facilities: Severe Respirator Supply Shortages, which modifies the earlier June 12 guidance in three significant ways:
- It does not include the extended re-use strategy whereby an employee is provided five or seven N95s that are rotated in use under specified conditions.
- While it allows hospitals to continue to disinfect N95s, it requires hospitals to store them for “future shortages.”
- It does not include the option for hospitals to provide facemasks for routine care of COVID-19 patients or persons under investigation.
These changes are premised on Cal/OSHA’s perspective that, “While supply chains for obtaining respirators are not fully restored, the supply of respirators for hospitals and other employers involved in patient care has improved to a point that prioritization of respirators for high hazard procedures and some other optimization strategies are not currently necessary.” The state stockpile is considered part of that supply, although there have been mixed results in fit testing the N95s provided by the state.
In addition, the guidance provides some relief with respect to fit-testing. While not a model of clarity, Cal/OSHA Chief Parker has assured CHA that the intent of the guidance is to provide a blanket allowance for hospitals to postpone annual fit testing through November 6. Cal/OSHA has adopted some other modifications to fit-testing protocols but did not adopt all the modifications authorized by Fed/OSHA.
CHA submitted various concerns about the June 12 guidance. Unfortunately, those concerns were not addressed in the updated guidance. CHA will continue to advocate for a reasonable approach to balancing the obligations of the Aerosol Transmissible Disease Standard with the reality of the continued shortage of N95 respirators. Please contact Gail Blanchard-Saiger with any operational issues you are facing or expect to face in light of this new guidance. (8/13)