OSHA Releases Pandemic Guidance for Healthcare Personnel
By Eric Toner, M.D., May 24, 2007
On May 21, 2007, the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor released Pandemic Influenza Preparedness and Response Guidance for Healthcare Workers and Healthcare Employers.1 This 104-page document provides a concise yet comprehensive overview of the occupational health issues related to hospital pandemic preparedness. It is clearly written and provides enough detail to make it quite useful for operational level personnel in healthcare institutions.
OSHA states explicitly that the document is intended to be advisory, not a standard or regulation, and therefore it creates no new legal obligations. On the other hand, the document reiterates that current OSHA regulations require that healthcare institutions protect their employees from recognized hazards and that this document is “intended to assist employers in providing a safe…workplace.”
The guidance also acknowledges that the available information on seasonal influenza transmission is incomplete,2 and, furthermore, “the transmission characteristics of a pandemic influenza virus will not be known until after the pandemic begins.” The document bases its guidance, for the most part, on seasonal influenza and states clearly where key information is missing or in doubt. For example, it points out that “[n]o study has definitively established airborne transmission as a major route of influenza transmission, but multiple studies suggest that some airborne influenza transmission may occur.” Thus, the authors caution that “given that the exact transmission pattern or patterns will not be known until after the pandemic influenza virus emerges, transmission-based infection control strategies may have to be modified to include additional selections of engineering controls, personal protective equipment (PPE), administrative controls, and/or safe work practices.”
The guidance points out that in a pandemic the risk of infection varies considerably among different employees within the same facility. Likewise, care may be provided in nontraditional settings, thus requiring individual risk assessment and carefully tailored policies and procedures for pandemic preparedness. In other words, when it comes to pandemic planning, one size does not fit all.
The guidance addresses many of the more difficult problems in hospital pandemic preparedness, including the likely shortage of N95 respirators. It explicitly recommends that healthcare facilities stockpile respirators in advance and discusses the potential reuse of respirators. Noting that while there is no data on the reuse of respirators for infectious diseases, “if a sufficient supply of respirators is not available during a pandemic, healthcare facilities may consider reuse as long as the device has not been obviously soiled or damaged (e.g., creased or torn), and it retains its ability to function properly. Reuse may increase the potential for contamination; however, this risk must be balanced against the need to provide respiratory protection for healthcare workers.”
The document emphasizes that advance preparations are key. Regarding respiratory protection it says, “If employers prepare appropriately, respiratory protection against pandemic influenza will be more effective. . . . Acquiring adequate supplies of appropriate respirators, ensuring that they fit key personnel, conducting appropriate training, and performing other aspects of respiratory protection can be accomplished in advance of a pandemic influenza outbreak. These measures should be repeated annually, prior to a pandemic being declared, to assure continued preparedness.”
Regarding training the guidance notes, “Training for a pandemic is essential to ensure continued effective operation of the facility. Cross-training and volunteer training for essential functions should be initiated early in pandemic preparedness planning. If advance training is not an option, then ensure that protocols and resources for just-in-time training are in place. If possible, identify pools of back-up staff or volunteer staff and begin training these individuals in infection control practices and respiratory protection (including fit testing) to ensure smooth integration in the healthcare facility in the event of a pandemic.”
Throughout the document, the authors have attempted to be consistent with existing HHS and CDC pandemic guidance3 as well as relevant JCAHO standards. The document is thoroughly referenced and provides many links to other useful resources, and the appendices include a number of practical tools. This document is a valuable resource and essential reading for those who are charged with readying healthcare facilities for the next pandemic.
Occupational Safety and Health Administration, U.S. Department of Labor. Pandemic Influenza Preparedness and Response Guidance for Healthcare Workers and Healthcare Employers. OSHA 3328-05. 2007. Available at: http://www.osha.gov/Publications/OSHA_pandemic_health.pdf. Accessed on May 23, 2007.
Brankston G, Gitterman L, Hirji Z, et al. Transmission of influenza A in human beings. Lancet Inf Dis2007;7:257–265.
Department of Health and Human Services Pandemic Influenza Web site.http://www.pandemicflu.gov/plan/healthcare/index.html.