New OSHA Flu Prevention Compliance Directive for Healthcare Workers

OSHA issued new compliance directive on November 20 to address flu prevention for healthcare workers. This directive is intended to minimize or eliminate high- to very-high-risk occupational exposures to the 2009 H1N1 influenza A virus. OSHA’s definition of “Very High-Risk Exposure” is “A job task or activity involving a medical or laboratory procedure during which there is a potential of occupational exposure to high concentrations of suspected or confirmed 2009 H1N1 influenza virus,” such as “Healthcare workers (for example, doctors, respiratory therapists, nurses, emergency responders, or dentists) performing aerosol-generating procedures on suspected or confirmed patients.” This includes skilled nursing facilities and home healthcare agencies. Additionally, as part of this new compliance directive, certain employers may be responsible for reporting cases of 2009 H1N1 influenza as part of OSHA injury and illness recordkeeping.

New Inspections
OSHA Compliance Safety and Health Officers (CSHOs) shall conduct inspections in workplaces likely to have high- to very-high-risk exposures to 2009 H1N1 influenza, where workers’ occupational activities involve close contact with patients or contaminated material in a healthcare or clinical laboratory setting. These inspections will be conducted in response to worker complaints, referrals (including media referrals), or as part of fatality and/or catastrophe investigations. As part of this inspection, CSHOs shall initially determine whether the employer has a written pandemic influenza plan as recommended by the CDC. CSHOs will also request all information regarding worker training programs and other methods used to inform workers of the hazards associated with exposure to 2009 H1N1 influenza or in preparation for an influenza pandemic.

Training Requirements
All employers, compliance, and training managers should be aware that this directive (excerpted below) provides specific recommendations for training:

“Employees should be provided with training on influenza prevention and risks of complications of influenza. In addition, employees should be informed of the vaccination protocol including the benefits and risks for vaccine, engineering controls, administrative controls, and the use of personal protective equipment protection during high-risk aerosol-generating procedures.”

Recommended Care2Learn Training
Care2Learn’s online course “H1N1 Influenza Outbreak: Planning and Response for Healthcare Professionals and First Responder Personnel (p1185)” addresses all of the recommend training requirements for this latest OSHA directive:

- Vaccination protocol including the benefits and risks for vaccine 
- Engineering controls 
- Administrative controls 
- Personal protective equipment protection