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Avian Flu Plan: Appendices > Appendix C <- You Are Here

Appendix C: Engineering Controls, Administrative Controls, Work Practices and Personal Protective Equipment for Protection from Pandemic Influenza Including Avian (H5N1) Influenza

Prepared by the Department of Environmental Safety (DES)
Latest Version of Protocol: August 12, 2008

NOTE of CAUTION: Since information related to Pandemic Influenza or Avian Influenza is subject to frequent and significant changes, readers of this document should check with DES to ensure they have the most recent version.

I. Characteristics of Influenza Transmission
Influenza (the flu) is a contagious respiratory illness caused by influenza viruses. It can cause mild to severe illness, and at times can lead to death. The best way to prevent the flu is by getting a flu vaccination each year.

Flu viruses spread mainly from person to person through coughing or sneezing of people with influenza. Sometimes people may become infected by touching something with flu viruses on it and then touching their mouth or nose. Most healthy adults may be able to infect others beginning 1 day before symptoms develop and up to 5 days after becoming sick. That means that you may be able to pass on the flu to someone else before you know you are sick, as well as while you are sick.

Humans can be infected with influenza types A, B, and C viruses. Wild birds are the natural host for all known subtypes of influenza A viruses. Avian influenza virus strains are further classified a low pathogenic (LPAI) or highly pathogenic (HPAI). The H5N1 virus is an influenza A virus subtype that occurs mainly in birds, is highly contagious among birds, and can be deadly to them. H5N1 virus does not usually infect people, but infections with these viruses have occurred in humans. Most of these cases have resulted from people having direct or close contact with H5N1-infected poultry or H5N1-contaminated surfaces.

As of August 2007, H5N1 has not been detected in North or South America and a pandemic influenza virus has not yet emerged.
II. Definitions
Seasonal (or common) flu is a respiratory illness that can be transmitted person to person. Most people have some immunity, and a vaccine is available.

Avian (or bird) flu (AI) is caused by influenza viruses that occur naturally among wild birds. Low pathogenic AI is common in birds and causes few problems. Highly pathogenic H5N1 is deadly to domestic fowl, can be transmitted from birds to humans, and is deadly to humans. There is virtually no human immunity and human vaccine availability is very limited.

Pandemic flu is virulent human flu that causes a global outbreak, or pandemic, of serious illness. Because there is little natural immunity, the disease can spread easily from person to person. Currently, there is no pandemic flu.

Respirator: OSHA considers a respirator to be "a protective facepiece, hood or helmet that is designed to protect the wearer against a variety of harmful airborne agents." Respirators must be selected based on the hazards that the wearer may be exposed to. Surgical/medical procedure masks are not considered to be respirators. OSHA requires that employers select respirators that are certified through NIOSH testing criteria.

Filtering facepiece: a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of filtering material (e.g., N95, N99 or N100). These types of respirators are tested and approved based on ability to filter particle size. They may help reduce exposures to airborne biological contaminants such as influenza virus; however they will not eliminate the risk of exposure, infection or illness.

Facemasks: loose-fitting disposable masks that cover the nose and mouth. These include products labeled as surgical, dental, medical procedure, isolation and laser masks. Facemasks are designed to prevent biological particles from being expelled by the wearer into the environment. Some surgical masks are fluid resistant to splash and splatter of blood and other infectious materials; however they are not necessarily designed to seal tightly to the face and may allow air leakage around the edges. Facemasks are not designed to protect the wearer against breathing in very small particles.

Neither a facemask nor a respirator will give complete protection from the flu.
III. OSHA Occupational Exposure Risk Categories Applied to UM Facilities and Job Duties.
A. According to OSHA, the level of employee risk to occupational exposure to influenza during a pandemic depends in part on the following:
1. The job assignment requires close proximity to people who are potentially infected with pandemic influenza. Close contact is considered to be within 6 feet since that is the range that large infectious droplets can travel or

2. The job assignments require either repeated or extended contact with known or suspected sources of pandemic influenza.
B. OSHA's occupational exposure risk categories are as follows:
1. Very High Exposure Risk: Healthcare occupations with high potential exposure to high concentrations of known or suspected sources of pandemic influenza during specific laboratory or medical procedures.
a. Healthcare employees (e.g., doctors, nurses, dentists) performing aerosol-generating procedures on known or suspected patients.

b. Healthcare or laboratory personnel collecting or handling specimens from known or suspected pandemic patients

c. At UM, this would include healthcare staff at the University Health Center who perform these procedures.
2. High Exposure Risk: Healthcare occupations and those with duties which result in a high potential for exposure to known or suspected sources of pandemic influenza virus.
a. Healthcare delivery and support staff exposed to known or suspected pandemic patients (e.g., doctors, nurses, hospital staff entering patients' rooms.)

b. Medical transport of known or suspected pandemic patients in enclosed vehicles (e.g., emergency medical technicians)

c. Performing autopsies on known or suspected pandemic patients

d. At UM, this might include University Health Center healthcare providers, support staff who must enter patient rooms, those who transport symptomatic ill persons to a hospital or to University Health Center, and healthcare providers and support staff who must have frequent close contact with symptomatic ill persons in temporary satellite healthcare facilities (e.g., residence halls that house ill students.)
3. Medium Exposure Risk: job duties which require frequent, close contact (within six feet) of the general public, groups of students or groups of employees.
a. Examples include schools, high population density work environments, high volume retail.

b. At UM, this would include employees who work in public areas and perform duties that require frequent, close contact with the general public, groups of students or groups of employees.
4. Lower Exposure Risk: job duties which have minimal or no contact with the general public, groups of students or groups of employees
a. This might include office workers and clerical staff.

b. At UM, this would include employees who work from home, work alone in an office or other location or are able to maintain six feet or more distance from others.
IV. OSHA's Hierarchy of Controls for Exposure Risk
A. According to OSHA, the best way to control a hazard is to remove it from the workplace, rather than relying on employees to reduce their exposure. A combination of control methods will often be used.

B. In preferred order, most workplaces will use a combination of engineering controls, administrative controls, work practices, and personal protective equipment.
1. Engineering Controls involve making changes to the work environment to reduce work-related hazards. They are preferred because they are permanent changes and do not rely on employee or customer behavior, which is hard to sustain.
a. Examples of these controls are the installation of clear plastic sneeze guards, drive through customer service windows or other barriers between employees and a possible or known source of the virus.
2. Administrative Controls include controlling an employee's exposure by scheduling their work tasks in ways that minimize exposure levels.
a. Examples include developing policies that encourage ill employees to stay home without fear of reprisal, telecommuting, flexible work hours, cancellation of face to face meetings and other social distancing measures.
3. Work Practice Controls are procedures for safe and proper work that are used to reduce the duration, frequency or intensity of exposure. These controls include:
a. Instructing employees to avoid close contact (within 6 feet) of other employees and the general public

b. Providing resources that promote personal hygiene such as tissues, no-touch trash cans, hand soap, hand sanitizers, and disinfectants and disposable towels for employees to clean their own work surfaces.

c. Encouraging employees to obtain a seasonal influenza vaccination to prevent illness from seasonal influenza

d. Providing employees with up-to-date education and training on influenza risk factors, protective behaviors, and cough etiquette.
C. UM will assess appropriate intervention strategies in workplaces and within job duties to determine appropriate controls
V. OSHA's Guidance on Personal Protective Equipment (PPE) Based on Workplace/Occupational Exposure Risk (see IIIB).
A. According to the CDC, neither a facemask nor a respirator will give complete protection from the flu. Engineering and administrative controls and work practices must be considered before the use of PPE is required

B. Very High or High Exposure Risk (see IIIB (1) (2))
1. A NIOSH/FDA approved N95 or higher filter respirator

2. Surgical respirator when both respiratory and resistance to blood and body fluids is necessary

3. Medical or surgical gowns or other disposable protective clothing

4. Gloves

5. Eye protection if splashes are anticipated.
C. Medium Exposure Risk (see III B (3)) (Note: It is possible that a higher level of respiratory protection would be recommended for some situations such as working with crowds or for a severe pandemic. The University will monitor these conditions and make those determinations on a case by case basis.)
1. Surgical mask

2. If surgical masks are not available, a reusable face shield that can be decontaminated may protect against droplet transmission.

3. Eye protection is not generally recommended.

4. Gloves are not generally necessary, but if worn, employees must wash hands thoroughly after removal.
D. Lower Exposure Risk (see IIIB (4)) (Note: It is possible that a higher level of respiratory protection would be recommended for some situations such as working with crowds or for a severe pandemic. The University will monitor these conditions and make those determinations on a case by case basis.)
1. General hygiene and social distancing methods should be reinforced

2. Personal Protective Equipment is not considered to be necessary.
VI. UM Procedures for Respirator Use

UM will follow guidance and/or requirements provided by OSHA, CDC or other federal or state agencies. The following assumptions apply:
1. The level of protection provided by respirators and facemasks during a pandemic is not known. It is assumed that neither will provide complete protection from exposure to pandemic flu.

2. It is expected that respirators and facemasks will be in short supply during a pandemic. UM will follow federal and state guidelines to limit respirator use to actual waves of a pandemic and only when the outbreak is local.

3. Disposable respirators such as the N95 are for one use only. When the respirator is contaminated, it cannot be decontaminated and must be discarded.

A. Very High and High Risk Workplaces; Medium Risk Workplaces with High Frequency Close Contact with Symptomatic Ill Persons
1. Only NIOSH-approved particulate (or higher protection) respirators may be used. Particulate respirators are categorized as N95, N99 or N100. Respirators used by health care workers must be FDA-approved.

2. Employees who wear respirators must be enrolled in the University's Respiratory Protection Program).

Requirements of this program include:
a. Medical clearance must be obtained from or through the Occupational Health Unit of the University Health Center.

b. Individuals must be trained by DES and be successfully fit tested before the respirator may be used. Facial hair that compromises the seal between the face and the respirator is not permitted. If accommodations for facial hair are deemed necessary for medical, religious or other reasons, the department / unit head will be advised by DES of the need to purchase a powered-air purifying respirator which does not require a tight seal.

c. Respirators are to be used for the specified conditions only. Use of respirators for other purposes must be approved by DES.

d. Respirators must be used, stored and repaired in accordance with the manufacturer's recommendations and the University Respiratory Protection Program.

e. Respirators cannot be shared and disposable respirators must be discarded after use or if contaminated or damaged.

f. The purchase and replacement of respirators is the responsibility of the employee's department.
B. Medium Risk Or Lower Risk Workplaces Where Respirator Use Is Not Required Bases On OSHA Criteria, but is Determined To Be Necessary By Department or Major Unit Head
1. DES must be notified by the department / major unit head of the intent to require respirator use in the workplace at least two weeks prior to placing an order for respirators or enforcing use. The name(s) and job titles(s) of the individuals must be provided.

2. DES will assist the department / major unit head in selecting the appropriate type/size(s) of respirators to be ordered. The department / major unit head is responsible for ordering and funding all costs associated with respirator use.

3. The department / major unit head must make arrangements to obtain a medical clearance for the individual(s) prior to use of the respirator.

4. The department / major unit head must contact DES to arrange for training and fit testing of the employee(s) once medical clearance(s) has been obtained and the respirator(s) has been received.

5. An adequate supply of respirators must be purchased since replacement is necessary when they become contaminated, soiled, damaged or wet.

6. The department / major unit head is responsible for instructing employees when they should wear the respirator during an Avian Flu outbreak. It is important to note that prolonged use of a respirator increases the physical demands on the cardiopulmonary system and should be avoided.

7. All other aspects of the Respiratory Protection Program will apply. A copy of the program may be accessed at (http://www.des.umd.edu/os/respirator/manual/index.html).

8. DES will not entertain requests to use a respirator from individual employees. The decision to require respirator use for purposes other than those listed in A is the responsibility of the department / unit head.
C. Respirator Use Is Requested By An Employee But Not Required By A or B (Voluntary Personal Equipment).
1. The department / major unit head may provide or permit use as long as it will not create a hazard to the employee. Possible hazards include use of a dirty or contaminated respirator or interfering with an employee's ability to work safely (e.g., reducing vision while driving or operating heavy machinery.)

2. If a filtering facepiece respirator (e.g., N95, N99, and N100) is used, the department / major unit head is not required to obtain a proof of medical ability to wear the respirator although employees should be encouraged to check with their health care provider.

3. If an elastomeric respirator (half or full face made from elastic polymer using cartridge or filter) or a supplied air respirator is worn, the department / unit head is required to make arrangements to obtain a medical clearance for the employee.

4. The department / major unit head must provide the employee with a written copy of "Instructions for Employees who Request Voluntary Use of a Respirator," which contains a copy of OSHA 1910.134, Appendix D, Voluntary Use of Respirators, and maintain a signed copy of Appendix D documenting that the employee has received it.

5. The department / major unit head is not required to purchase the respirator but may choose do to so.

6. Fit testing is not required for voluntary use.
VII. Reference Sources:
Occupational Safety and Health Administration (OSHA) (OSHA)

Department of Health and Human Services, Centers for Disease Control & Prevention (CDC) (CDC)

Food and Drug Administration (FDA)

World Health Organization (WHO)

U. S. Implementation Plan for the National Strategy for Pandemic Influenza

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