Unit
- Occupational Safety and Health Administration (OSHA): OSHA's PPE standards (29 CFR 1910 Subpart I) require employers to perform hazard assessments, provide appropriate PPE at no cost, and train employees on proper use. The standard applies to all general industry, including healthcare, manufacturing, and construction.
- Centers for Disease Control and Prevention (CDC): The CDC provides guidelines for PPE use in healthcare settings, particularly for infection control. The 2007 Guideline for Isolation Precautions recommends PPE based on the mode of transmission of infectious agents.
- Hierarchy of Controls: PPE is the last line of defense after elimination, substitution, engineering controls, and administrative controls. Employers must first attempt to reduce hazards through higher-level controls before relying on PPE.
- Employer Responsibilities: Employers must conduct a written hazard assessment, select proper PPE, provide training covering when and how to use PPE, and enforce consistent use. Training must be documented and updated when changes occur.
- Employee Responsibilities: Employees must use PPE as trained, inspect it before each use, report defects or malfunctions, and participate in training sessions. Failure to comply can result in disciplinary action.
- Recordkeeping Requirements: OSHA requires employers to maintain records of hazard assessments, PPE training sessions, and any workplace injuries related to PPE. These records must be available for inspection.
- Standard Precautions: In healthcare, standard precautions assume all blood and body fluids are potentially infectious. Gloves, gowns, masks, and eye protection are used based on the task and potential for exposure.
- Enforcement and Penalties: Noncompliance with OSHA's PPE standards can result in citations and fines. Willful violations can exceed $100,000 per incident. Regular internal audits help maintain compliance.
- National Institute for Occupational Safety and Health (NIOSH): NIOSH certifies respirators through the NIOSH Approval Program, ensuring they meet minimum filtration and performance standards. Employers must select NIOSH-approved respirators when respiratory protection is required, and employees must be fit tested and medically cleared before use.
- American National Standards Institute (ANSI): ANSI standards provide voluntary consensus specifications for PPE including hard hats (ANSI Z89.1), safety glasses (ANSI Z87.1), and protective footwear (ANSI Z41). While not legally binding, OSHA often references ANSI standards as evidence of industry best practice and adequacy.
- PPE Selection Criteria: Selection must be based on the specific hazard, task duration, exposure level, and compatibility with other PPE. For example, chemical-resistant gloves are chosen by permeation rate rather than material alone, and eye protection must shield against impact, splash, or optical radiation as needed.
Scope of Practice
Role: PPE Compliance Officer in Healthcare Facility
Within scope:
- Conduct hazard assessments for all patient care areas and support zones.
- Select and procure PPE that meets NIOSH and FDA standards.
- Develop and deliver PPE training for all clinical and nonclinical staff.
- Monitor PPE usage through direct observation and provide corrective feedback.
- Maintain documentation of training, inspections, and incident reports.
Outside scope:
- Diagnose medical conditions or treat patients.
- Modify clinical protocols without infection control committee approval.
- Discipline employees for noncompliance (referred to management).
- Conduct medical evaluations for respirator fit testing (requires licensed professional).
Regulatory Note
Regulation: OSHA 29 CFR 1910.132 requires employers to assess workplace hazards and select appropriate PPE. Training must include when PPE is necessary, what type is needed, how to properly don/doff, limitations, and proper care.
29 CFR 1910.132 (General requirements).
Quick Revision
- OSHA mandates hazard assessments, proper PPE selection, and training for all covered industries.
- CDC guidelines focus on isolation precautions and transmission-based PPE in healthcare.
- PPE is the lowest level in the hierarchy of controls and must not substitute for higher-level protections.
- Both employers and employees have documented responsibilities for PPE use and maintenance.