Short Take on OSHA Biohazards
By Susen Trail | 04/22/2020
OSHA standards have very limited coverage of biohazards. Even 1910.1030, the Bloodborne Pathogen standard only related to exposure to human blood, totally ignoring the variety of diseases, such as coronaviruses, that can be transmitted from animal blood or saliva to humans via inhalation or contact with mucous membranes. These would include transmission of bubonic plague from prairie dogs to pets and then to humans via fleas, and transmission of rabies from the saliva in bites from infected animals.
So, when looking for guidance from OSHA regarding protection of employees from a biological hazard there are only peripheral standards that apply. For example, the Respiratory Protection standard,1910.134, was written primarily for chemical or physical (such as clogged airways) hazards. However, the first sentence of 1910.134(a)(2) broadens the scope to apply to biohazards “A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee.”
Due to the shortage of respirators OSHA has had to make some concessions in the stringent requirements in 1910.134 to allow for the unprecedented increase in employees wearing N95 respirators:
- “Healthcare personnel (HCP) are exposed to patients with suspected or confirmed coronavirus disease 2019 (COVID-19) and other sources of SARS-CoV-2 (the virus that causes COVID-19).
- Protection of workers exposed to other respiratory hazards is impacted by the shortage resulting from the response to the COVID-19 pandemic. Such workplace respiratory hazards may be covered by one or more substance-specific health standards.”
The accommodations to the scarcity of N95 Filtering Facepiece Respirators, FFR’s (dust masks that are NIOSH certified) is an enforcement guidance to CSHO’s (Compliance Safety and Health Officers, affectionately called ‘Coshows’.) The link above carefully details the conditions under which the employer may allow all employers to the extended use or the reuse of N95 FFRs and the use of expired N95 FFRs.
If you have employees wearing respirators, for any reason, please be sure to train the employees AND have them demonstrate to you that they know how to remove the respirator. Keep in mind, everything you did not want them to inhale is now on the outside of the respirator where it might be shaken loose and inhaled or get on the employees hands where it can be absorbed or transferred to the face, etc. Studies show viable viral particles in break rooms and meeting rooms supposedly protected from contamination.