Is Your Employer Following the Plan?
New CalOSHA Regulations for ATD Exposure Control
In addition to the SEIU checklist for H1N1 infection control program elements,
there is a new comprehensive worker protection standard in California (effective August 5, 2009) that provides detailed mandatory requirements for infection control policies to protect healthcare workers from aerosol spread diseases, including H1N1 influenza (as a novel disease). It covers health care, emergency, public safety and some other workers (public and private) – but only in California. Federal OSHA is looking at it as a model for the nation.
We have included below (taken from pages 14 – 16 of the ATD) a list of elements required in the written Aerosol Transmissible Diseases Exposure Control Plan.
Download the complete ATD Exposure Control Plan:
CalOSHA ATD Standards
CalOSHA Section 5199: Aerosol Transmissible Diseases.
(d) Aerosol Transmissible Diseases (ATD) Exposure Control Plan.
(1) The employer shall establish, implement, and maintain an effective, written ATD Exposure Control Plan (Plan) which is specific to the work place or operation(s), and which contains all of the elements in subsection (d)(2).
(2) The Plan shall contain all of the following elements:
(A) The name(s) or title(s) of the person(s) responsible for administering the Plan. This person shall be knowledgeable in infection control principles and practices as they apply to the facility, service or operation.
(B) A list of all job classifications in which employees have occupational exposure.
(C) A list of all high hazard procedures performed in the facility, service or operation, and the job classifications and operations in which employees are exposed to those procedures.
(D) A list of all assignments or tasks requiring personal or respiratory protection.
(E) The methods of implementation of subsections (e) - Engineering and Work Practice Controls, and Personal Protective Equipment, (g) Respiratory Protection, (h) Medical Services, (i) Training and (j) Recordkeeping as they apply to that facility, service or work operation. Specific control measures shall be listed for each operation or work area in which occupational exposure occurs. These measures shall include applicable engineering and work practice controls, cleaning and decontamination procedures, and personal protective equipment and respiratory protection.
(F) A description of the source control measures to be implemented in the facility, service or operation, and the method of informing people entering the work setting of the source control measures.
(G) The procedures the employer will use to identify, temporarily isolate, and refer or transfer Airborne infectious disease cases or suspected cases to Airborne Isolation rooms, areas or facilities. These procedures shall include the methods the employer will use to limit employee exposure to these persons during periods when they are not in airborne infection isolation rooms or areas. These procedures shall also include the methods the employer will use to document medical decisions not to transfer patients in need of airborne infection isolation.
(H) The procedures the employer will use to provide medical services, including recommended vaccinations and follow-up, as required in subsection (h). This shall include the procedures the employer will use to document the lack of availability of a recommended vaccine.
(I) The procedures for employees and supervisors to follow in the event of an exposure incident, including how the employer will determine which employees had a significant exposure.
(J) The procedures the employer will use to evaluate each exposure incident, to determine the cause, and to revise existing procedures to prevent future incidents.
(K) The procedures the employer will use to communicate with its employees and other employers regarding the suspected or confirmed infectious disease status of persons to whom employees are exposed in the course of their duties, in accordance with subsection (h).
(L) The procedures the employer will use to communicate with other employers regarding exposure incidents, including procedures for providing or receiving notification to and from health care providers about the disease status of referred or transferred patients, in accordance with subsection (h).
(M) The procedures the employer will use to ensure that there is an adequate supply of personal protective equipment and other equipment necessary to minimize employee exposure to Aerosol Transmissible Pathogens, in normal operations and in foreseeable emergencies.
(N) The procedures the employer will use to provide initial and annual training in accordance with subsection (i) to employees in job categories identified in subsection (d)(2)(B).
(O) The procedures the employer will use for recordkeeping, in accordance with subsection (j).
(P) An effective procedure for obtaining the active involvement of employees in reviewing and updating the exposure control plan with respect to the procedures performed in their respective work areas or departments in accordance with subsection (d)(3).
(Q) Surge procedures. Employers of employees who are designated to provide services in surge conditions, and employers of employees who are designated to provide services to persons who have been contaminated as the result of a release of a biological agent as described in subsection (a)(1)(B), shall include procedures for these activities in the plan. The plan shall include work practices, decontamination facilities, and appropriate personal protective equipment and respiratory protection for such events. The procedures shall include how respiratory and personal protective equipment will be stockpiled, accessed or procured, and how the facility or operation will interact with the local and regional emergency plan.
(3) The ATD Plan shall be reviewed at least annually by the program administrator, and by employees regarding the effectiveness of the program in their respective work areas. Deficiencies found shall be corrected. The review(s) shall be documented in writing.