Establish a Respiratory Protection Program Protocols, respirator tests and documentation required BY LISA BERUS

Surgery centers never had to have a full respi- ratory protection pro- gram before now, but due to the COVID-19

pandemic and the consequent use of respirators, they might soon have to write and implement one. The Occupa- tional Safety and Health Administration (OSHA) requires healthcare organiza- tions to follow the OSHA Respiratory Protection Standard 29 CFR 1910.134 when using respirators. The rule states that anytime staff is required to wear a respirator, a written respiratory protec- tion program has to be in place. ASCs are currently under an emergency use authorization for respirators but as supplies become available, ASCs will have to fully comply with OSHA. To get started on writing a program, ASCs need to appoint a respiratory protection program administrator. The administrator of a center or the infec- tion control coordinator would likely be the program administrator. The pro- gram administrator should begin by conducting a hazard assessment at the ASC, focusing on who needs to wear a respirator. They should look at the job title of each employee and their indi- vidual tasks to make those decisions. Intubation, for instance, would be con- sidered a hazardous task and require wearing a respirator. A couple different kinds of respi-

rators are available in the market for healthcare professionals: filtering face- piece respirators (FFR) are the N95 or KN95 masks. They are disposable and fairly inexpensive. Powered air puri- fying respirators (PAPR) are often used for surgeries such as total joint replacement. They come with a hood and a battery that blows air in and out

of the hood. They are reusable and fairly expensive.

The OSHA standard requires every- one to be fit tested for their FFR respi- rator. PAPRs are loose-fitting and do not require a fit test. Every ASC should develop a medical evaluation question- naire for its staff that includes pulmo- nary lung questions to rule out emphy- sema and make sure that the employees who are required to wear a respira- tor can wear it safely. A physician or a nurse should look at the evaluation to decide which employees could wear a respirator safely. Two kinds of fit tests can be admin- istered: quantitative and qualitative. The quantitative test requires a piece of equipment that measures the actual amount of leakage into the face piece. The machine that makes those mea- surements, however, is expensive and requires a hole to be punched in the respirator, thus rendering it unusable for a second time.

ASCs usually run the qualitative test. In the qualitative test, a staff member wears a hood and someone sprays a bit-


ter or a sweet taste in it. If the respirator fits right, the wearer is not able to taste the substance. If it is too loose or does not fit right, the wearer is able to taste it. If the taste comes through, the test begins all over again with a different sized res- pirator and repeats until the wearer finds a hood that fits properly and is not able to taste any of the substances sprayed dur- ing the test. The test takes about 15 min- utes, and the hood is good for multiple uses. The respirator make, model, style and size are recorded, and that respirator is what the staff member must wear. The fit testing needs to be done upon hire and annually, and the ASC needs to document which mask fits whom. The annual testing could be omitted as long as an employee has not had any physi- cal changes. To determine whether an employee has had physical changes, they should fill out a questionnaire that asks if they have lost or gained weight or had any dental work done. To fit an N95, an employee cannot have facial hair at the sealing surface of a respira- tor; a moustache, sideburns or a goatee might work but not a full beard.

The advice and opinions expressed in this column are those of the author and do not represent official Ambulatory Surgery Center Association policy or opinion.

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