For many healthcare employers, the Covid-19 pandemic was the beginning of a workplace respirator program. Most did not have a respirator program prior to the pandemic, and are looking forward to returning to that, but aren't sure how to make that decision moving into 2021.
Without a fairly detailed dive into the specific of your workplace, existing safety policies, types of procedures performed, patient screening methods used, regulations specific to your healthcare sector, and a variety of other risk factors, we cannot advise on a specific course of action. For employers looking for professional guidance of this type, we offer consulting services and can provide a proposal.
For healthcare employers making this determination themselves, they should carefully review Cal/OSHA's Aerosol Transmissible Diseases regulation, California Department of Public Health requirements, and any local City/County guidelines, and consider the following:
Will employees be seeing confirmed or suspected Covid-19 patients?
If you are, for example, a medical clinic that will be seeing patients with respiratory or flu symptoms for evaluation and diagnosis, or you are a dental office that will have to provide emergency care for patients who have Covid 19, Cal/OSHA's aerosol transmissible diseases standard requires a full respirator program (with fit testing and training renewed annually).
If you are not seeing confirmed or suspected Covid-19 patients, conduct screening of all patients (recognizing fully the limitations of symptom and history based screening methods that will not detect asymptomatic and presymptomatic individuals), you have more leeway in determining whether to continue with a respirator program.
One important point is the nature of healthcare often requires providing urgent or emergency care to patients who may either have Covid-19, or have other fairly common upper respiratory symptoms that would meet the criteria for potential Covid-19 infection.
Will employees be required to wear a respirator? Remember: an "N95 mask" is a respirator.
Regardless of risk, if employees are required to wear a respirator for any work tasks, you must implement a full respirator program (with fit testing and training renewed annually).
Are there other regulations or third party standards requiring a respirator program?
Even though you may not be required to maintain a respirator program by Cal/OSHA requirements, there may be public health requirements specific to your industry that require it. Or, third party organizations may require it as part of their accreditation standards.
How has the availability of vaccination changed risk factors in the workplace?
There is always a benefit from decreased community transmission, but the impact on vaccination programs in your specific organization depends on a variety of factors, including the willingness of your workers to take the vaccine (and, related, your company policy on requiring them as a condition of employment). Significant ambiguity still exists regarding the duration of protection offered by the vaccine, and its effectiveness against emerging variants of Covid-19.
Is a respirator program needed for other pathogens?
Many employers have discovered that even with a decreasing threat from Covid-19, they still have a need for a respirator program (and in fact, should have had one all along). Particularly within medical clinics and hospitals, there may be a need to protect certain classes of employees from pathogens like tuberculosis. Dental professional may have to provide emergency care to a patient who also has a respiratory illness, and need a higher level of protection than would be provided by a procedure mask.
How effective are other safety controls used in the workplace?
Personal protective equipment like a respirator should be used when there are not other ways to effectively manage a hazard. Safer work practices and engineering controls, like isolation shielding or air purifiers, should be the first line of defense. The more effective these methods are, the less need there is for a respirator. Unfortunately, quantifying the effectiveness of controls against biological contaminants is not as easy as it is for chemical contaminants (where a variety of well-established methods exist to measure airborne concentrations)...so there's a fair amount of research and more qualitative professional judgement required here. A lack of effective safety controls, or ambiguity about their effectiveness means a respirator program should be maintained.
Would a respirator program, even if not required, improve workplace conditions?
Just as they did in early 2020, many employers deciding they will continue to maintain a respirator program through 2021 for all clinical staff, to keep everyone as safe as possible, which paid dividends in terms of morale, employee retention, and job satisfaction in the midst of the pandemic. There are also benefits in terms of reduced workforce disruption (less need to quarantine employees with potential exposure if they are wearing appropriate protective equipment).