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OSHA issues H1N1 Enforcement procedures

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November 23, 2009


OSHA issues H1N1 Enforcement Procedures

OSHA has just released their Enforcement Procedures to ensure uniform inspections of healthcare facilities for worker protection against H1N1 influenza—basing them on the
CDC interim guidance on infection control measures for 2009 H1N1 flu in healthcare settings, including protection of healthcare personnel.

The inspections will be initiated primarily in response to worker complaints and will focus on an assessment of the employer’s worker protection program, to include the following:

  • Implementing a hierarchy of controls to reduce the risk of transmission.
  • Encouraging worker vaccination.
  • Documenting worker exposures and medical follow-up.
  • Showing evidence of staff training about risks of H1N1 flu, how to reduce occupational risk of infection, appropriate personal protective apparel (e.g., respiratory protection), and sick leave policy.
  • Using respiratory protection at least as effective as fit-tested NIOSH-approved N95 respirators for:
    • Tasks with very high occupational exposure risk to H1N1, including the performance of aerosol-generating procedures, such as bronchoscopy, sputum induction, endotracheal intubation and extubation, open suctioning of airways, cardiopulmonary resuscitation and autopsies.
    • Tasks with high occupational exposure risk to H1N1, including entering rooms of H1N1 flu patients, having close contact (within 6 feet), or transporting them in enclosed vehicles.
  • Using a surgical N95 respirator when fluid precautions (e.g., blood splashes) are needed in
    addition to respiratory protection e.g., in the OR. (Surgical N95s are certified by NIOSH and cleared by the FDA.)
  • Showing an effort to monitor the supply of N95s and to prioritize their use according to the CDC guidance.

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