If you have any questions, email Gwen Borlaug at firstname.lastname@example.org
What rules and regulations guide PPE policy development for local health departments?
Program development at the local health departments is guided by OSHA General PPE Requirements Standard 29 CFR 1910 Subpart I and Wisconsin COMM Chapter 32. The National Institute of Occupational Safety and Health (NIOSH), an agency within the Centers for Disease Control and Prevention (CDC), is responsible for conducting research and making recommendations for the prevention of work-related illnesses and injuries. NIOSH and OSHA have released guidance documents for instituting a PPE program.
What are the critical components of a PPE program?
A written PPE program consists of:
- Hazard assessment
- Equipment selection and use
How often should the PPE Policy and Procedures be updated?
They should be reviewed annually and as needed per agency protocol. Depending on the outcome of this review, they may need to be updated. For example, it may be necessary to reassess the workplace hazard situation periodically to identify and evaluate new equipment and processes, review accident records, and reevaluate the suitability of previously selected PPE.
Who should be the PPE program's administrator?
The program administrator should possess skills and knowledge in infection control practices, communicable disease investigation and follow-up, and environmental heath hazards including airborne dust, mist, particles, or vapors, liquid chemicals, objects that can strike, crush, puncture, scrape, bruise, or cut, overhead materials, and loud noises. In addition, the administrator should possess skills identified as essential for all public health workers by the Council on Linkages between Academia and Public Health Practice in 2001 including:
- Analytic/Assessment Skills
- Policy Development/Program Planning Skills
- Communication Skills
- Basic Public Health Sciences Skills
- Cultural Competency Skills
- Financial Planning and Management Skills
- Leadership and Systems Thinking Skills
- Community Dimensions of Practice Skills
How often does the employer need to provide training for staff requiring PPE?
Initial training must be done prior to use of PPE, and thereafter when an employer has reason to believe that an employee does not understand PPE use, or when there are changes in the workplace or types of PPE that render previous training obsolete.
Who can provide training?
There are no specific requirements for the person assigned to provide training; however, it is best to select someone with knowledge in this area.
How should PPE be stored?
Generally PPE should be stored in a dry area at room temperature, protected from dust and moisture. Check with the manufacturer for more specific storage conditions. Some items may have expiration dates and will require rotation of stock to avoid outdating.
What are examples when public health would require use of PPE?
Some examples include:
- Wearing an N95 respirator when providing Directly Observed Therapy (DOT) for a client with active tuberculosis (TB)
- Wearing gloves when drawing blood
- Wearing earplugs when assessing a windstorm site where chain saws are in use to clear trees blocking roadways
- Wearing a hardhat when inspecting a kitchen at construction site for a new restaurant
- Wearing shoe covers when investigating a human health hazard complaint about animal feces in a home
Where and how do I document use of PPE in an emergency or disaster?
In an emergency situation when the Incident Command System (ICS) is used, the Incident Action Plan Safety Analysis (ICS-215A) form should be completed by the Safety Officer in accordance with the agency's PPE Program. The 215A form includes the recommended PPE to be used to respond to a public health emergency. The Operational Planning Worksheet (ICS-215) form may be used to track and document the type and number of PPE resources that are required, on hand, and needed during an event. ICS forms ICS-215 and ICS-215A are available at National Incident Management System Implementation > FDA Incident Command System (ICS) Forms. The Site Safety and Health Plan for PPE (ICS-208-CG SSP-F) Form is available to document the PPE equipment and procedures used for all-hazard situations and is available at http://www.uscg.mil/forms/ics/ICS_208_CG.pdf.
How much and what type of PPE should be stockpiled by home health agencies, group homes, EMS, and fire departments?
These agencies are responsible for providing their employees with current day-to-day supplies of appropriate PPE as well as ensuring that sufficient supplies are available during a public health emergency. PPE should be ordered directly from suppliers, as other sources such as hospitals or public health agencies will not have stockpiles to distribute to employers in their area.
Will the local health department provide PPE to other emergency responders in a public health emergency?
Under OSHA standards(Standard 29 CFR 1910 Subpart I) employers are required to provide PPE to reduce hazardous exposure to their employees. However, the local health department may consider procuring PPE for other responders that have responsibilities built into the local Public Health Emergency Plan (PHEP). This should be included in the local hazard assessment analysis to answer the question, "Have you included emergency responders /volunteers in your local PHEP plan that may require use of PPE?"
Should local health departments purchase supplies of respirators or masks for use by the general public?
No. You should not purchase these items for the general public. Consider having these items on hand only at mass clinics or local health departments where members of the general public may present with signs and symptoms of communicable diseases.
Does the general public need PPE?
No, there currently are no specific recommendations or requirements for the general public to purchase, use or stockpile PPE. In May 2007, the FDA cleared for marketing two special types of N95 respirators for use by the general public to add to their home medical emergency kits: http://www.infectioncontroltoday.com/hotnews/75h96523064049.html. This type of PPE is available to help reduce a person's exposure to airborne germs during a range of public health medical emergencies, such as a worldwide outbreak (pandemic) of influenza or a biological terrorist threat such as anthrax. The two respirators (called the 3M N95 Respirator 8612F and 8670F) are available to the general public to purchase without a prescription. The use of face masks or respirators may be helpful for persons at higher risk of complications from pandemic influenza or for those who must be in close contact with others during a pandemic. Note: The general public does not have to follow any state or federal laws to use these PPE devices that employers are required to follow, such as medical evaluation, fit testing and training.
What is the definition of a volunteer for the purposes of coverage by OSHA standards?
OSHA defines a volunteer as someone who receives no form of compensation from the entity using the services of the volunteer. This includes uniforms and meals. However, an occasional celebration that includes a meal does not negate volunteer status.
Are local health departments required to provide PPE to volunteers, partners and others from outside their agency who volunteer to respond to assist their agency?
Healthcare workers and other volunteers assigned to assist in a public health emergency will be treated and provided the same protections as employees, under OSHA law. Volunteers will be provided training, supplies and equipment at no cost to them on how to safeguard and protect themselves during the emergency response as appropriate, including use of PPE. To the extent possible, volunteers will not be assigned to perform tasks with potential hazardous exposure.
What type and level of PPE does a volunteer need?
Volunteers should use only the type and level of PPE they are assigned to use and provided training to use. This should never include any advanced level PPE or high-level, hazardous materials level equipment.
If volunteers need respiratory PPE that requires medical evaluation and fit testing, should the receiving agency require the volunteers to have their own medical evaluation and fit testing done, or does my home agency have to provide it?
The receiving agency, not the volunteer, is responsible for providing medical evaluation, fit testing and training to those needing respiratory protection. Volunteers should be given the same protections, including use of all appropriate PPE, as employees when responding to an event.
If a local public health agency enlists the aid of employees from other agencies or from volunteers during a public health emergency, is the local public health agency required to provide PPE for them as if they were their own employees?
Local public health agencies should protect volunteers and employees from other agencies in the same way they protect their own employees.
Is fit-testing and medical evaluation required during a public health emergency?
There may be limited time when deploying people to respond to an emergency.
All components of a respiratory protection program should be conducted during a public health emergency, including fit-testing, medical evaluation, and training, in order to protect employees and volunteers to the greatest extent possible. However, OSHA officials have indicated that health care organizations will not be fined for practices that occur during an infectious disease outbreak.
If I work for another agency as a volunteer, which PPE policies and procedures do I follow - ones from the agency I work for or from the agency I volunteer to work for?
Follow all safety procedures, including PPE use, from the agency for which you are volunteering. It is the responsibility of the receiving agency to provide staff and volunteers with training on the PPE to use to respond to the event before the PPE is issued to you.