The Occupational Safety and Health Administration (OSHA) has issued guidance for compliance safety and health officers on the reuse of filtering facepiece respirators (FFRs) that have been decontaminated.
The guidance recognizes the severe shortage of personal protective equipment (PPE), and N95 FFRs in particular, that health care providers have faced during the COVID-19 pandemic. To address the shortage of N95s, many health systems and the New York City Department of Health and Mental Hygiene have implemented FFR sterilization programs. These programs allow health systems to effectively decontaminate used FFRs and give them back to health care workers for safe reuse.
The OSHA guidance offers the following prioritized decontamination methods evaluated by the National Institute for Occupational Safety and Health (NIOSH): If these methods are not available, OSHA provides alternative options in its memo.
- Vaporous hydrogen peroxide
- Ultraviolet germicidal irradiation; and/or
- Moist heat
The OSHA memo provides alternate options if these methods are not available.
OSHA also includes the following specific enforcement guidance for employers in organizations where workers are using decontaminated FFRs:
- Make a good-faith effort to provide and ensure that workers use the most appropriate respiratory protection available for the hazards against which workers need to be protected.
- When respirators must be decontaminated to facilitate their reuse, ensure that decontamination is accomplished according to the methods described above and detailed in the Center for Disease Control and Prevention’s Decontamination and Reuse of Filtering Facepiece Respirators using Contingency and Crisis Capacity Strategies.
- Ensure that users perform a user seal check each time they don a respirator. Employers should not permit use of a respirator on which the user cannot perform a successful user seal check.
- Train employees to follow appropriate precautionary measures prior to using a decontaminated FFR.
- Train employees using decontaminated respirators to understand that if the structural and functional integrity of any part of the respirator is compromised, it should not be used by that individual as respiratory protection. The inability to achieve a successful user seal check could be an indicator that the integrity of the respirator is compromised.
- Visually inspect, or ensure that workers visually inspect, the FFRs to determine if the structural and functional integrity of the respirator has been compromised.
- Train employees on the procedures for the sequence of donning/doffing to prevent self-contamination.
- If no manufacturer or third-party guidance or procedures are available to support the specific decontamination method(s) employed, avoid the use of decontaminated FFRs when health care personnel perform surgical procedures on patients infected with, or potentially infected with, SARS-CoV-2, or perform or are present for procedures expected to generate aerosols or procedures where respiratory secretions are likely to be poorly controlled (e.g., cardiopulmonary resuscitation, intubation, extubation, bronchoscopy, nebulizer therapy, sputum induction).
The OSHA guidance builds on OSHA’s previously issued flexibilities around respirators, including for fit-testing, the use of respirators beyond the manufacturer’s recommended shelf life, extended use and reuse of respirators, and the use of alternative equipment certified by NIOSH or in accordance with standards from other countries and jurisdictions.