High Interest Topics
CalOSHA and COVID-19 Isolation
New Non-emergency Standards were released last month:
Most of our LTC facilities do not have Airborne Infection Isolation Rooms (AIIR) / negative pressure rooms. SARS CoV2 is an aerosol pathogen per CA Regulation Title 8 Section 5199. Specific exemptions apply when caring for persons with COVID-19. Application of Exceptions requires careful and regular documentation. Many of our Marin County buildings have older or non-compliant ventilation systems. In these cases you must implement and document specific accommodations when caring for COVID-19 Positive persons (persons with Novel Respiratory Pathogens or Airborne Infectious Pathogen-AirIP). This may include assessment of ventilation, use of in-room HEPA filters, exhaust ventilation via window when done per regulation, and of course proper respiratory precautions for all staff and visitors entering such areas. Additional resource Cal/OSHA - COVID-19 Non-Emergency Regulations FAQs
See also section (d) (2) (E) of 5199: “Specific control measures shall be listed for each operation or work area in which occupational exposure occurs. These measures shall include applicable engineering and work practice controls, cleaning and decontamination procedures, and personal protective equipment and respiratory protection.” This would be included in your Aerosol Transmissible Disease Plan per Section 5199.
When caring for persons with COVID-19 (Air-IP) in Non-Airborne Infection Isolation Room (AIIR) settings (i.e. when not in negative pressure rooms) you are operating under Section 5199 EXCEPTIONS to Subsections (e)( 5) (B). In most instances this will be under Exception #2: “Where it is not feasible to provide [Airborne Infection Isolation - AII] rooms or areas to individuals suspected or confirmed to be infected with or carriers of novel or unknown ATP (aerosol transmissible pathogen).” In this case, “employer shall provide other effective control measures to reduce the risk of transmission to employees, which shall include the use of respiratory protection in accordance with subsection (g) and Section 5144, Respiratory Protection of these orders.” This includes putting into place specific protections. NOTE: Exceptions do not apply for when high risk procedures are performed such as intubation; in such cases AIIR or use of PAPR as additional measures are recommended.
Ventilation: Refer to CA Regulation 3205.1 COVID-19 Outbreaks section (f): (f) Ventilation. In buildings or structures with mechanical ventilation, employers shall filter recirculated air with Minimum Efficiency Reporting Value (MERV)-13 or higher efficiency filters if compatible with the ventilation system. If MERV-13 or higher filters are not compatible with the ventilation system, employers shall use filters with the highest compatible filtering efficiency. The employer shall use High Efficiency Particulate Air (HEPA) air filtration units in accordance with manufacturers' recommendations in indoor areas occupied by employees for extended periods, where ventilation is inadequate to reduce the risk of COVID-19 transmission.
CalOSHA COVID-19 Resources
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