This week, OSHA issued temporary enforcement guidance for Healthcare Respiratory Protection for the duration of the COVID-19 pandemic. On March 11, 2020, the President directed the Department of Labor to take all appropriate and necessary steps to increase the availability of general use respirators for emergency use by personnel in healthcare facilities due to concerns of supply shortages. In response, OSHA issued temporary enforcement guidance to its Respiratory Protection standard. (29 CFR § 1910.134) The Respiratory Protection standard has specific requirements, including a written program, medical evaluation, fit testing, and training, that employers must follow to ensure workers are provided and are properly using appropriate respiratory protection when necessary to protect their health. One of the most vital changes is that healthcare employers may change the method of fit testing from a destructive method, called quantitative, to a non-destructive method, called qualitative.  Both methods are effective at determining whether the respirator fits properly but the qualitative type conserves the filter for future use. Some other examples of the changes to the standard for the duration of the pandemic are:
  • OSHA field offices will exercise enforcement discretion concerning the annual fit testing requirement
  • healthcare employers may provide staff with another respirator of equal or higher protection
  • OSHA updated a document called “Strategies for Optimizing the Supply of N95 Respirators”
OSHA is careful to stress that appropriate respiratory protection is still required for all healthcare personnel providing direct care of COVID-19 patients. For more information about this temporary enforcement guidance, see https://www.osha.gov/memos/2020-03-14/temporary-enforcement-guidance-healthcare-respiratory-protection-annual-fit For additional guidance, see COVID-19 Hospital Preparedness Assessment Toolhttps://www.cdc.gov/coronavirus/2019-ncov/hcp/hcp-hospital-checklist.html. For additional guidance, see Strategies for Optimizing the Supply of N95 Respirators, https://www.cdc.gov/coronavirus/2019-ncov/hcp/respirator-supply-strategies.html.3