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OSHA Seeks Public Comment on Workplace Stockpiling Guidance

By Kunal Rambhia, May 16, 2008

On May 9, 2008, the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor released proposed guidance on workplace stockpiling of facemasks and respirators for pandemic influenza and is seeking public comment. OSHA recommends workplace stockpiling “because manufacturing capacity at the time of an outbreak would not meet the expected demand” and “employers will be able to better protect their employees as well as lessen the impact of a pandemic on their business, society, and the economy.”¹ The guidance recommends that employers categorize employee positions into four risk types, “according to the likelihood of employees’ occupational exposure to pandemic influenza.”¹ The categories are:

1. Very High Exposure Risk: Healthcare or laboratory employees who perform tests on pandemic patients or work with patient samples in a laboratory
2. High Exposure Risk: Healthcare employees who work in patient rooms, transport patients, or perform autopsies on pandemic patients
3. Medium Exposure Risk: Employees who interact frequently with and have exposure to the general population
4. Low Exposure Risk: Employees with limited contact with patients or the general public

At each risk level, the guidance provides formulas for determining the number and type of respirators or facemasks needed and for calculating the total approximate cost of respirators and facemasks associated with a 120 day pandemic period. There is also a description of the types of respirators to use during a pandemic, including disposable, surgical, reusable elastomeric, and powered air purifying respirators. Additionally, the document provides benefits, drawbacks and price ranges for each type of respirator.

According to OSHA, although inexpensive, surgical facemasks provide only a physical barrier against “large droplets of blood or body fluids.”¹ In contrast, respirators “reduce an employee’s exposure to airborne contaminants;” however, they can cost between $0.50 and $1200 per unit, depending on the sophistication of the device.¹

The OSHA guidance is being offered as an appendix to Guidance on Preparing Workplaces for an Influenza Pandemic (jointly issued by the Department of Labor and the Department of Health and Human Services) which was released in February 2007. The new guidance document will be open for public comment until July 8, 2008, and instructions for submitting comments can be found at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=20383.

Reference

1. Occupational Health and Safety Administration. U.S. Department of Labor. Proposed guidance on workplace stockpiling of respirators and facemasks for pandemic influenza. May 9, 2008. http://www.osha.gov/dsg/guidance/stockpiling-facemasks-respirators.html. Accessed May 16, 2008.