The Occupational Safety and Health Administration inspections are increasing and OSHA is using data related to SNF COVID-19 – that is reported to the National Healthcare Safety Network.  As a reminder, OSHA requires all employers to report inpatient hospitalizations within 24 hours and fatalities within 8 hours when the event is work-related (OSHA Standard 1904.39).  Facilities must do their best to investigate and determine if a positive case is work-related or not, per the OSHA Standard 1904.5. Local Health Department contact tracing can be helpful in determining the source of positive cases.  If a case is determined to be work-related, it must be recorded on the OSHA 300 log and reported per applicable time frames. Remember to document, document, document when investigating and determining case origin.  OSHA released new guidance related to COVID-19 cases effective May 26, 2020.  It is at OSHA’s discretion to determine if the employer’s efforts were enough in determining if the case is work-related or not.  Important things to keep in mind and on hand;

• Have a written respiratory protection program (OSHA Standard 1910.134)
• Conduct a medical evaluation, by a trained medical professional, for employees who will need to wear N95 respirators.
• OSHA fit-testing requirements require all employees using an N95 mask, have an initial fit test. Should fit testing for initial use of the respirator be difficult to obtain, you need to maintain documentation that OSHA will review, to support your efforts in locating fit tests. Documentation should include evidence that and order was placed for fit tests that were not received or are on back-ordered.  Again, documentation of good faith efforts is key.
• CDC guidelines allow the use of non- National Institutes of Safety and Health approved respirators during the COVID-19 pandemic.  Those that are unable to be fit tested must be used according to the manufactures instructions on fit and wear and documentation and that the facility checked to ensure they are not on the Food and Drug Administration list of unapproved models. 

As always, please access the HealthCap Resources and Education Center for helpful information.