September 4, 2003

OSHA Docket Office
Docket No. H-049D
Technical Data Center
Room N-2625
U.S. Department of Labor
200 Constitution Ave., NW
Washington, DC 20210

Re: Revisions to OSHA's Respiratory Protection Standard (29 CFR Part 1910)

The American Association of Occupational Health Nurses, Inc. (AAOHN) and the Association of Occupational Health Professionals (AOHP) are pleased to provide a joint response to OSHA's proposal for an additional controlled negative pressure (CNP) fit testing protocol for its Respiratory Protection Standard (29 CFR Part 1910).

General Feedback
First, we applaud OSHA for opening Part 1910 up for comments. We support the proposal to simplify the standard, as the new CNP REDON fit testing protocol appears to save time by reducing the overall number of fit factors, and promotes better health and safety practices in the workplace through increased detection of respirator leaks.

While efficiency is a benefit of the proposed revision, we maintain the key issue is that personal protective equipment (PPE) should be a last resort to controlling hazards in the work environment, after feasible engineering and administrative and work practice controls have been exhausted. Respiratory protection can protect workers against airborne contaminants when the above control measures are unavailable or insufficient to control the hazard. Respiratory protection can also be appropriate in an emergency situation.

However, when a decision is made to use respirators, it is critical that the correct respirator for the hazard be selected. There needs to be a consistent approach in selecting the respirator, whether the hazard is an airborne infectious disease such as TB or SARS, or of a non-biological nature, such as asbestos or lead, etc. In addition to selecting the correct respirator, there still must be adequate fit testing based on the type of respirator and workers should be trained on the proper use, inspection, cleaning, maintenance, etc. of the respirator.

Most importantly, we urge OSHA to consider the fact that the need for respirators varies by industry, and recommend that protocols reflect the unique challenges and characteristics for employees in each work environment.

To that end, because OSHA has opened the respirator standard for review, AAOHN and AOHP would like to take this opportunity to provide additional comments on the issue of respiratory protection for workers in health care environments.

Addressing the Unique Needs of Health Care Workers
As it is currently written, Sec. 1910.134 applies to general industry, and provides clear, logical guidance to protect employees within this sector. However, much of the language in the general respirator standard, particularly the component that addresses fit testing requirements, does not translate well to a health care setting because:

• The primary need for respirators within a health care environment is to protect employees against airborne hazards that are very different from those to which employees in general industry are likely to be exposed (i.e. airborne infections such as smallpox, TB, SARS, vs. lead, asbestos, poisonous gas).
• There is a larger percentage of employees within a health care environment (versus general industry) who could potentially be exposed, and thus require respirator protection.
• Health care workers are more aware, due to ongoing training, about exposures to airborne infectious diseases than the employee in general industry.

AAOHN and AOHP recommend creating a respirator standard that will take into account these unique characteristics of a health care environment, while providing adequate protection from all airborne infectious diseases and other hazards. The need for a new, separate respirator standard to protect against airborne infections is underscored by the trend toward the emergence of newer, more virulent strains of infectious diseases that will continue to have worldwide impact.

We'd like to point out that OSHA has already examined these issues, and developed a respirator standard that has been effective in protecting health care workers: Sec. 1910.139. Because there is already a standard that adequately addresses the level of respirator protection required in a health care setting, we have the following specific recommendations:

• Rename Sec. 1910.139, "Respiratory Protection for M. Tuberculosis" to "Respiratory Protection for Airborne Infectious Diseases."
• Determine respiratory protection requirements for health care workers based on the size of the infectious microbe.
• Clearly define surveillance procedures under the standard in a way that promotes the protection of workers' health and safety, but in a way that is both practical and efficient. For example, conduct fit testing upon hire and then use annual surveys thereafter to determine any physical changes that affect the fit of the respirator.

Conclusion
Although AAOHN and AOHP support OSHA's proposal to simplify 29 CFR Part 1910, we believe personal protective equipment (PPE) should be a last resort to controlling hazards in the work environment, after feasible engineering and administrative and work practice controls have been exhausted.

And, since OSHA has opened the respirator standard for review, we recommend that the agency consider creating an additional respirator standard that will take into account the unique characteristics of a health care environment, and that provides adequate protection from all airborne infectious diseases and other hazards.

AAOHN and AOHP appreciate the opportunity to provide our input on this issue. As always, we will continue to support OSHA in promoting a safe and healthy work environment. We would welcome the opportunity to elaborate on the points outlined in this document. Please feel free to contact us at 919-966-0979 (AAOHN), or
412-578-6792 (AOHP) for clarification or additional information.

Sincerely,

Susan A. Randolph, MSN, RN, COHN-S, FAAOHN
President, AAOHN

MaryAnn Gruden, MSN, CRNP, NP-C, COHN-S/CM
Executive President, AOHP