OSHA Releases Respiratory Protection Guidance for LTCFs

The U.S. Occupational Safety and Health Administration (OSHA) has released Respiratory Protection Guidance for the employers of those working in long-term care facilities during the COVID-19 public health emergency.  This resource can be found in full here.

In responding to COVID-19, OSHA recommends long-term care facilities rely on engineering and administrative controls first.  For example, employers should reassess their engineering controls (i.e., ventilation) and administrative controls (i.e., hand hygiene, physical distancing, cleaning/disinfection of surfaces) to identify any changes that can be made.  However, even when control strategies are in place, PPE should be utilized in accordance with the Indiana Department of Health’s (IDH) Infection Control Guidance Standard Operating Procedure. 

Fit Testing

Importantly, whenever respirators are required under IDH’s Infection Control Guidance (Red and Yellow Zones), employers must implement a written, worksite-specific respiratory protection program, including medical evaluation, fit testing, training, and other elements, as specified in OSHA’s Respiratory Protection Standard (29 CFR 1910.134).  This requirement should be read in conjunction with OSHA’s March 2020 memorandum, which articulates a temporary policy under which OSHA will exercise enforcement discretion with respect to the annual fit testing requirements, as long as the employer conducts initial fit tests for each health care professional with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19.  Accordingly, initial fit tests must be conducted for each type of respirator utilized by employees.  If respirators from a new manufacturer are acquired, initial fit tests should completed once again.

Documentation

In order to exercise the discretion outlined in its memorandum, OSHA’s guidance states that employers must demonstrate and document good-faith efforts to comply with OSHA standards. This includes documenting all attempts to procure required PPE and conduct initial fit testing.

In creating or updating your facility’s respiratory protection program, AHCA/NCAL’s consultants with Littler Mendelson have developed a template respiratory protection program that can be tailored to your organization’s needs, should this resource be helpful.  If you have questions, please contact Laura Brown at Lbrown@ihca.org.

Other Resources

Please be sure to access IHCA/INCAL’s Fit Testing toolkit that is intended to guide the facility to implement the components of a Respiratory Protection Program that meets OSHA requirements, and addresses the evaluation, training, testing, and monitoring criteria needed for a successful facility system.