OSHA Issues H1N1 Enforcement Procedures Directive

OSHA has issued an agency-wide instruction establishing enforcement policies and providing instructions for its inspectors to minimize “high” to “very high” occupational exposure risk to the H1N1 virus. The directive, CPL-03-00-012, is a new initiative, and it is effective today.

The directive does not apply to medium or lower risk occupational exposures. OSHA considers medium-risk jobs as those with tasks or activities requiring frequent, close contact (within six feet) with the general public and others; teachers, bank tellers, and grocery store cashiers fall into this category, according to the directive. The lower risk category includes office workers and others who have minimal contact with the general public.

Today’s directive applies only to jobs the agency considers as a high or very high risk for occupational exposure. These jobs include health care workers (very high risk) – doctors, respiratory therapists, nurses, emergency responders, and dentists, as well as those performing aerosol-generating procedures on suspected or confirmed patients (such as sputum inductions, endotracheal intubations and extubations, bronchoscopies, and some dental procedures or invasive specimen collection. Other health care workers who have tasks or activities taking them within six feet of suspected or confirmed patients or into small, enclosed airspaces shared with patients (emergency transport staff, for example) are considered at high exposure risk.

The 46-page directive (available at www.osha.gov/OshDoc/Directive_pdf/CPL_02_02-075.pdf) notes that the 2009 H1N1 influenza is transmitted via direct or indirect person-to-person transmission of infectious droplets expelled when an influenza patient coughs, sneezes, talks, or even breathes. For transmission to occur, the expelled infectious droplets must subsequently make direct or indirect contact with the mucus membranes of the mouth, nose, or eyes of an uninfected person. The instruction adds that airborne transmission has been shown to be one of the potential routes of transmission but says that because there is a great need for more research on H1N1 transmission, workers involved in tasks or activities that place them at high to very high exposure risk must be offered protection from all possible routes of transmission (contact, droplet, and airborne) to ensure their protection.

OSHA’s directive closely follows CDC’s Interim Guidance on Infection Control Measures for 2009 H1N1 Influenza in Healthcare Settings, Including Protection of Healthcare Personnel, issued Oct. 14, 2009. That guidance offers assistance in analyzing occupational exposure and measures for protecting workers in health care settings and recommends protective measures during H1N1 waves when health care workers are performing tasks or activities where they will be expected to have close contact (within 6 feet) with suspected or confirmed H1N1 patients. The following industrial hygiene hierarchy of controls applies to high to very high occupational exposure risk to the virus identified as 2009 H1N1 influenza of workers whose occupational activities involve contact with patients or contaminated material in a health care or clinical laboratory setting:

1. Take steps to eliminate the hazard when feasible (e.g., postponing elective procedures for persons with suspected or confirmed influenza);
2. Use engineering controls to eliminate or reduce exposure (e.g., use airborne infection isolation rooms [AIIR] for very high exposure risk procedures);
3. Use administrative controls (e.g., provide and promote vaccination at no cost to employees);
4. Use work practices (e.g., promote hand hygiene and cough etiquette); and
5. Provide and ensure use of personal protective equipment, including respiratory protection, and provide proper training to affected employees.

The directive notes CDC also has published several checklists to assist employers in developing the minimum recommended components of 2009 H1N1 influenza preparedness plans. CDC checklists are available at www.flu.gov/professional/checklists.html. Other CDC resources on the 2009 H1N1 influenza can be accessed at www.cdc.gov/h1n1flu. In addition, OSHA has developed several documents to assist employers, some of which are listed in Appendix B of today’s instruction and others of which can be accessed on the agency’s 2009 Pandemic Influenza Safety and Health Topics page located at www.osha.gov/dsg/topics/pandemicflu/index.html and at www.flu.gov.

OSHA notes that states with OSHA-approved state plans must have their own inspection policies and instructions that are at least as effective as federal OSHA’s described in today’s directive, and they must be available for review. States are required to notify OSHA whether they intend to adopt policies and procedures identical to today’s Instruction or adopt or maintain different policies and instructions for conducting inspections to minimize high to very high risk occupational exposures to the virus identified as 2009 H1N1 influenza. If a state adopts or maintains policies and instructions that differ from federal OSHA’s, the state must identify the differences in its policies and either post its new or existing different policies on its State Plan Web site and provide the link to OSHA or provide a copy to OSHA and information on how the public may obtain a copy from the state. If the state adopts identical policies and procedures, it must provide the date of adoption to OSHA. OSHA said it will provide summary information on the state responses to today’s Instruction on its Web site.

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