With the COVID-19 outbreak creating a shortage of N95 filtering face piece respirators (FFRs), the world is diverting its limited supply to protect frontline healthcare workers and emergency responders.
Employers in non-healthcare industries are also facing the shortage and searching for alternatives for protecting their employees from exposure to airborne dust, mists and fumes.
As the demand increases for the foreseeable future, you should develop a plan to protect your essential employees exposed to airborne particles. Our safety experts rounded up recommended strategies for managing the N95 FFR shortage in a public health crisis.
Health and safety professionals use a framework called the hierarchy of controls to identify ways to control workplace hazards. The best way to control a hazard is to remove it from the workplace. When it might not be possible to eliminate or replace the hazard, the most effective protection measures are (listed from most effective to least effective):
1. Engineering controls
2. Administrative controls, which include safe work practices
3. Personal protective equipment (PPE)
When considering the ease of implementation, effectiveness and cost, there are advantages and disadvantages to each control measure. In most cases, a combination of control measures may be necessary to protect workers.
o Use wet methods to suppress dust to prevent it from becoming airborne.
o Use portable local exhaust systems to capture air contaminants at the source, before they can enter the employee’s breathing zone.
o Install dust collection systems to capture, convey and collect dust.
o Operate equipment within enclosed cabs or ventilated booths to isolate the employee.
o Prohibit cleaning methods such as dry sweeping, dry brushing and compressed air that can cause dust to become airborne and inhaled by employees.
o Perform wet sweeping or use high-efficiency particulate air (HEPA)-filtered vacuums to clean dusty surfaces.
o Schedule work so that tasks involving high exposures are performed when no other employees are in the area.
o Adjust work schedules or rotate job assignments to reduce exposure time so that no employee is overexposed.
o Move operations outdoors instead of performing dust-generating operations indoors or in an enclosed space.
o PPE should be considered a method of last resort when engineering and administrative controls are not sufficient to achieve acceptable limits of exposure.
When new controls are implemented, or changes are made to existing controls, employers should revise their job hazard analysis (JHA) for the affected job task. Any time a JHA is revised, training in the new job methods, procedures or protective measures should be provided to all employees affected by the changes.
If respirators must be used, ensure that only National Institute for Occupational Safety and Health (NIOSH) approved respirators are provided. Consider the following alternatives:
To address the shortage that’s due to the COVID-19 pandemic, OSHA released guidance for all industries on extended use and reuse of N95 FFRs and the use of expired N95 FFRs.
The released guidance highlights enforcement discretion to permit the extended use and reuse of respirators, as well as the use of expired respirators that are beyond their manufacturer’s recommended shelf life during the current public health crisis.
Employers should make a good faith effort to implement controls or use alternative classes of respirators before considering these time-limited options.
If the extended use or reuse of N95 FFRs becomes necessary, the same worker is permitted to extend the use of or reuse of the respirator, as long as the respirator maintains its structural and functional integrity and the filter material is not physically damaged, soiled, moist from sweat or contaminated (e.g., with blood, oil, paint).
Those working in the construction and industrial setting may find it difficult to maintain the structural and functional integrity of the respirator to allow extended use or reuse. Currently, there are no manufacturer authorized methods for FFR decontamination before reuse.
If the use of expired N95 FFRs becomes necessary, the Centers for Disease Control and Prevention (CDC) and NIOSH have recommended that expired N95 FFRs only be used as outlined in their Strategies for Optimizing the Supply of N95 Respirators and Stockpiled N95Respirators.
According to OSHA, when employees are required to use or permitted voluntary use of respiratory protection, employers must continue to manage their RPPs as required by the OSHA Respiratory Protection Standard, 29 CFR 1910.134.
The OSHA standard requires employers to identify and evaluate respiratory hazards in the workplace, develop and implement a written RPP with worksite-specific procedures, and update their written programs as necessary to reflect changes in workplace conditions that affect respirator use.
If you don’t have a program in place, use Pinnacol’s sample respiratory protection program to help you stay in compliance.