infection prevention
By Hillary Hei , MPH , CIC , LSSGB
Developing a Respiratory Protection Program
The response to the COVID-19 pandemic has emphasized the need for adequate protection against SARS-CoV-2 to ensure employee safety . Prior to the pandemic , most healthcare settings outside of acute care rarely needed to wear respiratory protection beyond a medical-grade facemask . With this abrupt shift in the need for respirator use , many facilities using respirators for the first time also need to adhere to
Whether your facility is experienced with an RPP or not , it is best to ensure your program is in compliance with OSHA regulations and that the program can be sustainably maintained . and maintain compliance with federal regulations . If respirators are used in a workplace , the U . S . Department of Labor ’ s Occupational Safety and Health Administration ( OSHA ) requires employers to follow the Respiratory Protection Standard 29 CFR 1910.134 , or OSHA state-plan equivalent . 1 This standard states that if staff must wear a respirator due to an identified hazard at work , a written respiratory protection program ( RPP ) is required .
From the start of the pandemic through Dec . 31 , 2020 , OSHA has issued numerous citations from more than 300 inspections for violations relating to COVID-19 , 2 identified either by complaints , referrals or severe incident reports . This has totaled more than $ 3.9 million in proposed penalties across many industries , with healthcare settings including hospitals , nursing homes , and long-term care settings .
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Whether your facility is experienced with an RPP or not , it is best to ensure your program is in compliance with OSHA regulations and that the program can be sustainably maintained . OSHA ’ s Respiratory Protection Standard 29 CFR 1910.134 has legally enforceable requirements when respirators are used , including :
Designate a respirator program administrator ( RPA ).
1 Each facility must designate one individual to be like an air-traffic controller for the complete RPP . This person is in charge of setting up and overseeing the program , with specific tasks such as maintaining all necessary records and arranging annual trainings and fit tests . This person does not need to be a licensed healthcare professional but should be “ qualified by appropriate training or experience 1 .”
Develop a written workplace-specific RPP and update
2 as necessary . The facility ’ s RPP must be relevant and specific to the worksite . OSHA also emphasizes the need to keep the program updated as necessary . Anytime a policy or procedure related to respirator use changes , this must be reflected in the RPP .
Complete a hazard assessment .
3 A hazard assessment is essential to identify potential hazardous exposures that require the use of respiratory protection while employees are on the job . It is important to consider all employee roles , duties , and responsibilities while performing this assessment .
Select the respirators that will be used based on the
4 hazard assessment . In healthcare settings , potential exposures to infectious pathogens may warrant protection against droplet or airborne transmission . If respirators are needed to provide reduced exposure to airborne hazards , it ’ s important to specify in your RPP which type ( s ) of respirator the facility will use ( e . g . N95s , elastomeric facemasks ).
Conduct medical evaluations .
5 Because respirator use may exacerbate underlying medical conditions , medical evaluations are required for each employee prior to donning a respirator for work or fit testing . Information solicited from evaluation questionnaires must be reviewed by a physician or other licensed healthcare professional , and the employee must be approved prior to using a respirator .
Complete respirator fit testing .
6 Fit testing is the most important part of the respirator program , and OSHA requires fit testing for all users of tight-fitting respirators . The test ensures that the brand make and size adequately reduces employee exposure from airborne hazards . This fit test must be repeated annually , whenever the employee reports changes in their physical condition , or when a different brand , type , or size of respirator is introduced to the employee for use . Facilities can perform fit tests through either a qualitative or quantitative fit test .
Educate employees .
7 Training is also essential , as staff must understand the limitations and capabilities of the respirator used . Users should know when a respirator is necessary , how to inspect , put on , and properly take off a respirator , and how to properly perform a seal check .
Maintain all necessary records .
8 The RPP requires all records to be maintained and readily available to staff and OSHA upon request . Staff medical questions , medical evaluation and clearance , fit testing records , and documentation of staff training must be kept .
The response to the pandemic has created an increased demand for respirators such as N95s and has resulted in supply chain issues in respirators and fit testing kits . OSHA is temporarily exercising enforcement discretion on a case-by-case basis when considering issuing citations related to improper respiratory protection during COVID-19 . Facilities must demonstrate and document “ good-faith ” efforts to comply with OSHA standards and any interim enforcement memoranda . 3 Interim provisions