OSHA's Proposed Guidance On Respirators And Facemasks
# 1987
OSHA, the Occupational Safety & Health Administration, released their proposed guidance for Workplace Stockpiling of Respirators and Facemask for Pandemic Influenza yesterday. OSHA is looking for public comment on these proposed guidelines, and will accept written submissions until July 8th, 2008.
As stipulated in yesterday's release, these guidelines are not yet adopted.
This proposed guidance reflects the current thinking on the stockpiling of respirators and facemasks for the purpose of pandemic influenza preparedness. The information contained in this document is distributed solely for the purpose of pre-dissemination public comment. It has not been formally disseminated by DOL. It does not represent and should not be construed to represent any agency determination or policy.
The proposed guidance is an illuminating read, and one I recommend everyone take time to examine. The numbers of PPE's that our health care system will require, based on OSHA estimates, is staggering.
The issue of stockpiling PPE's, particularly for hospitals, clinics, and first responders has been addressed repeatedly in this blog, including here, here, and here .
This OSHA report first defines levels of risk, based on potential exposure to infected individuals.
Occupational Risk Pyramid for Pandemic Influenza
Very High Exposure Risk:
- Healthcare employees (for example, doctors, nurses, paramedics, or dentists) performing aerosol-generating procedures on known or suspected pandemic patients (for example, cough induction procedures, tracheal intubations, bronchoscopies, some dental procedures, or invasive specimen collection).
- Healthcare or laboratory personnel collecting respiratory tract specimens from known or suspected pandemic patients.
High Exposure Risk:
- Healthcare delivery and support staff exposed to known or suspected pandemic patients (for example, doctors, nurses, and other hospital staff that must enter patients' rooms).
- Staff transporting known or suspected pandemic patients (for example, emergency medical technicians).
- Staff performing autopsies on known or suspected pandemic patients.
Medium Exposure Risk:
- Employees with high-frequency contact with the general population (such as schools, high population density work environments, and some high volume retail).
Lower Exposure Risk (Caution):
- Employees who have minimal occupational contact with the general public and other employees (for example, office employees).
Although I've run the numbers in a back-of-an- envelope calculation before, showing that our national stockpile of PPE's would be quickly exhausted in a pandemic, OSHA has put together some more detailed numbers.
Here is their estimate of mask use by hospital and EMS/First Responders in a single pandemic wave. Note, we may see multiple waves, and our ability to resupply in between waves may be severely limited.
(click to enlarge)
While TOTALS are not addressed in this study, a little third grade math paints a disturbing picture.
A small-sized County or City FIRE/EMS (ambulance/rescue) might have 100 first responders. Each would need nearly 1,000 N95 masks (8 per shift/120 days). That's 100,000 N95's, which when bought in bulk, would cost $50,000.
Nationwide, there are roughly 1 million Law Enforcement Officers, each would require 240 masks. That's 240 Million masks.
Numbers of HCW's that will be working during a pandemic are unknown, but according to the CDC, there are 12 million Health Care Workers in this country, 80% of whom are women.
It is probably safe to assume that many HCW's who now have limited contact with critically ill patients will be called upon to treat flu victims. If there are 8 Million HCW's providing direct care during a pandemic, and each requires 480 N95 masks, then we'd better have another 4 Billion masks in the storeroom.
And of course there will be plenty of non-HCW related jobs that must be done that will involve potential virus exposure.
Non-N95 masks, like surgical masks, will be needed for infected patients as well. The demands for these types of facemasks could run into the billions, as well.
The cost to protect a single employee (masks only) may run as high as $250-$330 dollars, add in gowns, gloves and decontamination supplies, and that price goes up.
For a medium sized hospital, with 600 employees directly involved in patient care, it could easily cost $300,000.
And of course, hospitals rely on a variety of support personnel; housekeeping, food service, security, maintenance, clerical, lab, and other specialties. I doubt many would be willing to work, even if they aren't in direct contact with infectious patients, without some protection.
The truth is, we need to spend billions of dollars just on masks, gowns, and gloves to protect our healthcare workers. And we need to do it now, before a pandemic erupts.
While the costs may seem high, the price we will pay if we fail to do this will be astronomical.
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