Airborne infectious disease


Recently I was working on updating our respiratory program, and training that both the employee and supervisor could easily understand and still meet OSHA 1910.134. How fortunate that on February 12, 2011 the DOL came out with a new training video.

The 33-minute video explains the major components of a respiratory protection program including fit-testing, medical evaluations, training, and maintenance. The video also discusses the difference between respirators and surgical masks, and features a segment on common respiratory hazards found in healthcare settings, including airborne infectious agents that cause diseases such as tuberculosis, pandemic influenza, severe acute respiratory syndrome (SARS), chicken pox, and measles.

Demonstrations also show how respirator use helps protect workers from exposure to airborne chemical hazards such as formaldehyde and glutaraldehyde, which are used commonly in hospital laboratories to preserve tissue samples for medical analysis. These toxic substances can cause eye and nasal irritation, headaches, asthma, and other symptoms. Additionally, formaldehyde is a carcinogen and has been linked to nasal and lung cancer, with possible links to brain cancer and leukemia.

“Employers can’t rely on respirators providing the expected protection if they don’t train their workers on how to use them properly,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “This video is an important training tool that teaches proper respirator use and discusses employers’ responsibilities under OSHA’s respiratory protection standard.”

Intended for both employers and employees, the 33-minute video covers the main components of a respiratory protection program, the difference between respirators and surgical masks, and common respiratory hazards in health care settings – including airborne infectious agents that cause diseases such as tuberculosis, according to an OSHA press release.

OSHA’s Regulatory Priorities

The Secretary’s vision of Good Jobs for Everyone requires a safe and healthy workplace for all workers. OSHA’s regulatory program is designed to help workers and employers identify and control hazards in the workplace and prevent injuries, illnesses and fatalities. OSHA’s current regulatory program demonstrates a renewed commitment to worker protection.

OSHA’s major projects to implement the Secretary’s vision are:

Airborne Infectious Diseases
Airborne infectious diseases such as tuberculosis, severe acute respiratory syndrome (SARS), and influenza can be spread from person-to-person. OSHA is interested in protecting the nation’s 13 million healthcare workers from airborne infectious diseases. Healthcare-acquired infections are on the rise and there are also increasing levels of drug-resistant microorganisms in healthcare settings. Most current infection control efforts are intended primarily for patient protection and not for worker protection. In March 2010, OSHA intends to publish a Request for Information to help examine how to improve worker protection from exposure to airborne diseases.

Occupational Injury and Illness Recording and Reporting Requirements (Musculoskeletal Disorders)
OSHA is proposing to revise its regulation on Recording and Reporting Occupational Injuries and Illnesses (Recordkeeping) to restore a column on the OSHA 300 Injury and Illness Log that employers will check when recording work-related musculoskeletal disorders (MSDs). The MSD data from the column will help about 750,000 employers and 40 million workers track injuries at individual workplaces, and improve the Nation’s occupational injury and illness information data published by the Bureau of Labor Statistics. The MSD column was removed from the OSHA 300 Log in 2003. The Agency will issue a proposed rule in January 2010.

Cranes and Derricks
More than 80 workers lose their lives each year in crane-related fatalities. OSHA’s existing rule, which dates back to 1971, is partly based on industry consensus standards that are over 40 years old. On October 9, 2008, OSHA issued a comprehensive proposed revision of the Cranes and Derricks standard. The proposed rule addresses electrocution hazards, crushing and struck-by hazards, overturning, procedures for ensuring that the weight of the load is within the crane’s rated capacity, and ensures that crane operators have the required knowledge and skills by requiring independent verification of operator ability. This year, OSHA completed the public hearing and comment phase of the process and is now analyzing the public’s input and preparing the final rule. OSHA plans to issue the final rule in July 2010.

Crystalline Silica
Inhalation of respirable silica dust can cause lung disease, silicosis and lung cancer. Exposure to airborne silica dust occurs in operations involving cutting, sawing, drilling and crushing of concrete, brick, block and other stone products, and in operations using sand products (e.g., in glass manufacturing and sand blasting). One study estimated that there may be as many as 7,000 new cases of chronic silicosis each year. This rulemaking will update existing permissible exposure limits and establish additional provisions to protect workers from exposures to respirable crystalline silica dust. OSHA plans to publish a Notice of Proposed Rulemaking in July 2010.

Combustible Dust
Combustible dust can cause catastrophic explosions like the 2008 disaster at the Imperial Sugar refinery that killed 14 workers and seriously injured dozens more. Deadly combustible dust fires and explosions can be caused by a wide array of materials and processes in a large number of industries. Materials that may form combustible dust include wood, coal, plastics, spice, starch, flour, feed, grain, fertilizer, tobacco, paper, soap, rubber, drugs, dyes, certain textiles, and metals. While a number of OSHA standards address aspects of this hazard, the Agency does not have a comprehensive standard that addresses combustible dust. OSHA is engaged in the early stages of rulemaking to develop a combustible dust standard for general industry. OSHA published an Advance Notice of Proposed Rulemaking in October 2009 and is preparing to hold stakeholder meetings in December 2009.

Hazard Communication Standard - Global Harmonization System of Classification and Labeling of Chemicals
OSHA and other U.S. agencies have been involved in a long-term project to negotiate a globally harmonized approach to informing workers about chemical hazards. The result is the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA is revising its Hazard Communication Standard to make it consistent with the GHS. The new standard will include more specific requirements for hazard classification, as well as standardized label components which will provide consistent information and definitions for hazardous chemicals and a standard approach to conveying information on material safety data sheets. On September 30, OSHA published the proposal and is preparing for hearings in March 2010.

Beryllium
Beryllium is a lightweight metal that has a wide variety of applications, including aerospace, telecommunications and defense applications. Chronic beryllium disease occurs when people inhale beryllium dust or fumes and can take anywhere from a few months to 30 years to develop. The disease is caused by an immune system reaction to beryllium metal, and causes symptoms such as persistent coughing, difficulty breathing upon physical exertion, fatigue, chest and joint pain, weight loss, and fevers. OSHA is developing a rule that would update the Permissible Exposure Limit and establish additional provisions to protect exposed workers. Currently, the Agency is preparing to conduct a peer review of the health effects and risk assessments and plans on initiating the peer review in March 2010.

Diacetyl
Employee exposure to diacetyl causes obstructive airway disease, including the disabling and sometimes fatal lung disease called bronchiolitis obliterans or “popcorn lung.” This rulemaking will establish a Permissible Exposure Limit as well as additional provisions to protect workers from exposure to diacetyl. OSHA held a stakeholder meeting on diacetyl in 2007 and completed the small business review panel report in July 2009. OSHA is currently working on the proposed regulatory text and developing the health, risk and feasibility analysis. The Agency plans to initiate a peer review of the health effects and risk assessments in October 2010.

Walking / Working Surfaces - Subparts D & I
This proposed standard will update OSHA’s rules covering slip, trip and fall hazards and establish requirements for personal fall protection systems. The rule affects almost every non-construction worker in the United States. This is an important rulemaking because it addresses hazards that result in numerous deaths and thousands of injuries every year. The proposal is expected to prevent 20 workplace fatalities per year and over 3,500 injuries serious enough to result in days away from work. The Agency plans to issue a proposal in March 2010.

OSHA recently solidified leadership for the agency and has provided a clearer picture of the regulatory horizon.

First of all, David Michaels, PhD, MPH, assumed his position as head of OSHA when the Senate confirmed his nomination as assistant secretary of Labor for occupational safety and health. Nominated by President Barack Obama on June 28, the Senate acted on the nomination December 3.

Michaels, an epidemiologist, has been a professor at the George Washington University School of Public Health and Health Services in Washington, DC, and is also the author of Doubt is Their Product: How Industry’s Assault on Science Threatens Your Health.

Agency watchers assumed that any work on new, and perhaps controversial, standards, would await the establishment of a permanent director.

While Michaels as settling in, Secretary of Labor Hilda L. Solis held an online Q&A session Dec. 7 to discuss regulations at the Department of Labor.

Solis announced that OSHA is considering airborne infectious disease protection for healthcare workers and will publish a request for information in the Federal Register in March.

A standard would require healthcare employers to protect workers from tuberculosis, severe acute respiratory syndrome (SARS), and influenza, such as H1N1, on which OSHA recently issued an enforcement directive.

When asked if an airborne infectious disease standard would be modeled after the California version, which took years to achieve consensus among employers, labor and other stakeholders, Solis said the California standard “would certainly be one important piece of information that OSHA will consider in deciding whether to propose or issue a standard.” She would not predict how long it would take to issue a final standard.

Also, Solis confirmed that although OSHA has conducted several inspections, it has not yet issued any citations based on the H1N1 enforcement directive.

In an OSHA-specific session later that day, HealthLeaders Media asked OSHA interim director Jordan Barab, if the absence of airborne infectious disease standard has hampered the agency with regard to its H1N1 educational preparedness and enforcement activities?

“No, it has not hampered us,” said Barab. “While a standard on airborne transmissible diseases would have been preferable, we believe that we are responding to the issues effectively using existing standards and the General Duty Clause.”

On the matter of issuing an industry-wide ergonomics standard, both Solis and Barab reiterated—word-for-word in fact—”At this time, OSHA has no plans for regulatory activity.” Both said that a proposal to reinstate the work-related musculoskeletal disorders column on the OSHA 300 Injury Log was not a prelude to issuing such a standard.

Concerning an industry-specific ergonomic standard, such as one for safe patient handling standard, Barab said,” There are many options that OSHA might consider if the agency decides to pursue rulemaking in this area. Industry specific standards is one option that would be considered.”


David LaHoda, the managing editor of Medical Environment Update and OSHA Watch, has produced healthcare training videos and consulted for medical practices and ambulatory healthcare facilities.