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Set Descending Direction
Exceptions from respiratory protection regulations allowing the use of surgical masks only apply to healthcare facilities and emergency medical services, the Occupational Safety and Health Administration (OSHA) reminded employers. Other employers must provide respirators, the agency explained in guidance discussing the differences among cloth face coverings, surgical masks, and respirators.

OSHA does not consider surgical masks or cloth face coverings suitable substitutes for respirators in complying with substance-specific standards, such as those for asbestos and silica. The agency encouraged employers to rely on the hierarchy of controls, eliminating or substituting out workplace hazards and using engineering controls, such as ventilation or wetting, and administrative controls like modification of task duration to limit exposures.

Agency guidance granted compliance safety and health officers (CSHOs) enforcement discretion related to respirator use. OSHA acknowledged it may be necessary to extend the use of or allow reuse of certain respirators, use of respirators beyond their manufacturer's recommended shelf life, or use of respirators certified under the standards of other countries or jurisdictions but that have not been evaluated or approved by the National Institute for Occupational Safety and Health (NIOSH).

Guidance from OSHA and the Centers for Disease Control and Prevention (CDC) covering crisis strategies to extend the supply of respirators was intended only for healthcare employers.

Other employers should delay a task if the task poses imminent danger and controls are not feasible and appropriate respirators are not available, according to OSHA. The task should be delayed until feasible control measures are available to prevent exposures or reduce them to levels at or below the agency’s permissible exposure limit (PEL).

Face coverings, surgical masks, respirators

Cloth face coverings are worn in public to prevent the wearer from infecting others from COVID-19 or other airborne infections, according to the agency. Worn in public over the nose and mouth, cloth face coverings contain the wearer's potentially infectious respiratory droplets produced when the infected person coughs, sneezes, or talks and can limit the spread of SARS-CoV-2, the virus that causes the coronavirus disease 2019 (COVID-19), to others.

Face coverings may be commercially produced or improvised—bandanas, scarves, or items made from t-shirts or other fabrics.

Face coverings are not considered personal protective equipment (PPE) and likely will not protect the wearer from transmissible infectious agents due to loose fit and lack of seal or inadequate filtration.

Surgical masks typically are cleared by the U.S. Food and Drug Administration as medical devices and usually are worn to contain the wearer's respiratory droplets—healthcare workers, such as surgeons, wear them to avoid contaminating surgical sites, and dentists and dental hygienists wear them to protect patients. During the ongoing pandemic, surgical masks are being used as a stopgap PPE measure for healthcare and emergency medical services workers to protect workers against splashes and sprays containing potentially infectious materials.

However, not all masks that look like surgical masks actually are medical-grade, cleared devices.

Respirators are used to prevent workers from inhaling small particles, including airborne transmissible or aerosolized infectious agents. Respirators like N95 filtering facepiece respirators must be provided and used in accordance with OSHA’s respiratory protection standard (29 CFR 1910.134).

The respiratory protection standard contains requirements for proper training, fit testing, medical evaluations and monitoring, cleaning, and program oversight by a knowledgeable staff member.


Despite the pressures leadership may feel to return to work, there is a core truth they may not want to face: Rushing back to the way things once were increases the risk of failure in the present.

The coronavirus pandemic is causing uncertainty in all corners of our society. People are anxious for life to return back “to normal,” but can’t envision what normal even looks like yet. Public officials are waiting on data and science to guide them to a benchmark that will tell them when it’s safe to end physical distancing, while business leaders are watching the clock and wondering if they’ll have a business to return to when this pandemic becomes less of a public health threat.

Despite the pressures leadership may feel to return to work, there is a core truth they may not want to face: Rushing back to the way things once were increases the risk of failure in the present.

The reason is because life is not what it was pre-pandemic. People change, equipment breaks down, the process is likely outdated. This is why most companies create what the safety industry calls a Management of Change (MOC) document. Simply put, the MOC is your best guarantee of preventing accidents and injuries that could be catastrophic. It identifies the added risks that have emerged since the crisis, creates a communication blueprint to make sure all the gatekeepers within the company are on the same page, and provides a guide to implement the changes to the operating procedure in a concise and thorough manner.

Before leadership makes the decision to start up production, the following questions need to be answered:

Will operations start back up with the same number of personnel?

Your workforce is the one thing that can change the most in a crisis. Companies tend to overlook this factor because it’s not obvious. But consider this scenario: What if the pandemic forced your company to furlough employees, resulting in some employees never returning? If this is the case, this now means your three-person control room team is now a single person, or it could involve a team that does not have the knowledge or experience of the team it replaced. That could create significant hazards to your procedures and more. A MOC would recognize the change and create a new process to accommodate your current workforce.

Were there any changes to the equipment during the shut-down or decreased operation period?

Physical distancing, the reliance on face masks and gloves—All of it is expected to be part of our lives in the distant future. So what does that mean for your shop floor? Your warehouse? You will likely have to modify your equipment to accommodate physical distancing. You will likely have to fit in more breaks because your employees are not used to wearing masks and could overheat. Once again, these are factors that you likely didn’t think of, but need to be addressed in your MOC.

Will your current procedures for training hold up?

The answer is simple: Likely not. It will be difficult to safely train everyone in a single room as before. A conference room that holds 75 people should only hold 25 people. Also, training rooms themselves could be redundant, especially now as more consultants are moving to virtual training in an effort to provide a safe environment on both sides of the computer screen.


As you might tell, a MOC is necessary to address inevitable changes ahead. Because you can’t underestimate the risks and hazards that can result from even seemingly minor changes. The MOC helps your organization follow a systemic process to identify risks and ensure that they are properly addressed before implementing changes.

In other words, a MOC program will force you to slow down and take a step back. This could potentially save lives. Think about all physical, process, procedural, personnel and organizational changes that have occurred. Some are made intentionally, and some are the result of the current pandemic: Staff cuts and physical distancing guidelines are just two examples.

A robust MOC program will address the basis for the change, the impact to safety and health, modifications to operating procedures, temporary or permanent changes, and the notification and training of all affected parties. You’ll be in safe hands when the new normal arrives.


With little federal guidance on how to reopen and operate workplaces during and post-pandemic, employers are questioning their responsibility to test or not test employees for coronavirus.

Workplaces will have to accommodate safety measures like social distancing and PPE—but should employers be testing workers for coronavirus, or taking temperatures?

That is the million-dollar question. Actually, the billion dollar question: Amazon said it plans to spend as much as $1 billion this year to regularly test its work force, while laying the groundwork to build its own lab near the Cincinnati airport, according to one NYT article.

Las Vegas casinos are testing thousands of employees as the city begins to reopen, and they are using primarily nasal sampling testing methods.

Even major league baseball teams are discussing regimens to test players and critical staff members multiple times a week.

By and large, employers want to test because they want to keep workplaces safe, yes. But mostly, it’s because the virus contracted or spread at the workplace could mean big legal trouble down the line.

The main issue with the question of employers’ responsibility to test is the dilemma of testing availability in the country. Public health experts and government officials have said that widespread testing will be critical to reopening US businesses, but there is little federal or clear guidance on the role employers should play in detecting and tracking coronavirus. As a result, businesses are largely responsible for sorting out whether or not to test—and how to do so.

“It is a really hard conversation because people want absolutes: ‘If I do this, will it guarantee I’ll have a safe workplace?’ None of the testing is going to provide that right now,” said John Constantine, the chief executive of ARCPoint Franchise Group, a nationwide lab network offering virus testing to employers. He added that if done smartly, testing could reduce health risks. “Even if it’s not perfect, some testing is better than no testing.”

There are two approaches to the idea of testing, too, the CDC explains. Diagnostic tests, for example, only detect infections during a certain period. Blood tests administered after infection only show if a person has coronavirus antibodies, but scientists are unsure about what COVID-19 immunity even looks like.

Other officials are saying widespread testing may be both unnecessary and cause for a false sense of security. Especially because a person can test positive for the virus one week and contract it the next.

However, despite lack of federal guidance on testing, the CDC released checklists to help schools and businesses in various industries decide to reopen.

At the very least, many workplaces like pharmacies and food service workplaces have been taking employee temperatures at the start of each shift. If a person has a temperature over 100 degrees, they are sent home.

However, a lot will depend on the nature of each workplace, officials say. For example, factories and meatpacking plants with employees already close together will likely need to test workers more often than will corporate offices with less in-person interaction.

According to the COVID Tracking Project, testing has increased to about 400,000 people a day. Nearly 13 million tests have been completed, according to the CDC, accounting for less than four percent of the population. It is unclear how many of the tests are diagnostic and how many are for antibodies.

One nascent strategy circulating among public health experts is running “pooled” coronavirus tests, in which a workplace could combine multiple saliva or nasal swabs into one larger sample representing dozens of employees. The technique—used during WWII to test soldiers for syphilis—would allow companies to see whether there is coronavirus circulating among workers. A positive result would lead to further individual testing within a group.

The future of what America’s workplaces will look like continues to be a burning question. Testing is likely to be a big part of that conversation.


Welcome back. In the last issue, we discussed the concept of self-triggering and the importance of learning how to self-trigger quickly, or at least quickly enough to prevent making a critical error, which means that we have to train the sub-conscious mind.

Now, to a certain extent, we have already discussed the importance of involving or using the subconscious mind to prevent injuries when we talked about developing good habits with eyes on task, so that if or when your mind goes off task, you’ll still get the benefit of your reflexes. Habits and reflexes are not things we are deciding to do in the moment with our conscious mind. They are both subconscious.

Dealing with skeptics

All this is where the neuroscience comes in. Until the last 10 years or so, scientists and psychologists could speculate as to what part of the brain was being used. But it wasn’t until FMRIs that they could prove it. And I think that it’s interesting how the neuroscience and the critical error reduction techniques are aligned or how the neuroscience supports or validates the critical error reduction techniques. But my dad, who is an engineer, was unimpressed. When I explained it to him, he said that it was one of the best examples of “locking the door after the horse has got out” he’d ever heard.

His point was that the CERTs (critical error reduction techniques) were around for 10 years before they started doing experiments with FMRIs so if the CERTs didn’t work, they would have been “dead and gone” long before the neuroscience was published. So he’s got a point. But it’s still pretty interesting. And it is science which always helps when dealing with skeptics.

We’re going to get into at least a bit of it as we go through all four critical error reduction techniques. Two of which we have discussed already: work on habits, or work on improving your safety-related habits and self-triggering on the states (rushing, frustration, fatigue) so you don’t make a critical error. And obviously, this has to happen quickly. Even if it’s only a split-second too late, it’s still too late. And in order to get close to reflex speed, we need to use the subconscious mind.

The subconscious mind

The conscious mind just isn’t quick enough. Ironically, training the subconscious mind — isn’t quick—and when you think about learning arithmetic, it wasn’t always exciting either. To give you an example of speed, repetition and the power of the subconscious mind, just answer the following question as quickly as you can: What is 3 x 4? You probably already have the answer in your head before you read it here. It’s 12. That’s how quick your subconscious mind is. But how many repetitions did it take to get that quick so you didn’t have to process anything? Now try 13 x 14.

Like the example above, you could probably do the calculation in your head, but not before you read the answer, which is 182 — or before you were seriously hurt in a motor vehicle collision on the highway or fell down the stairs at work. That’s how fast self-triggering has to be. Repetition is the key to training your subconscious. It’s like someone walking over a grass field. Not much changes. But if two or three people walk over it, then twenty or thirty, pretty soon you have a path. And as more and more people walk over it, it gets wider.

And it’s much the same with neural pathways. The more it’s repeated, the faster it gets. And just like the path through the grass field, it doesn’t matter how smart the people are who are doing the walking, it’s just about the back and forth — the repetitions. What you’re trying to achieve is that “instant sense of danger” that you get when you see a snake or look down from a really high cliff. Only now that sense of danger has to happen — as soon as you start to rush, as soon as you start to feel frustrated and as soon as you start to feel tired.

And just like the grass, the key is repetition: getting people to keep associating rushing, frustration and fatigue with risk to develop that sub-conscious sense of danger. Which brings us back to the moment, so we can use our conscious brain to keep our eyes and mind on task. So even though there are no shortcuts to training you subconscious, with enough stories and repetition you can learn how to self-trigger quickly enough to prevent making a critical error.

If only it was so easy with complacency. Complacency is different than rushing, frustration or fatigue in that you can’t notice it very easily in the moment. It’s something that happens over time.

As you get used to something, like driving 60 mph/100 km/h, although there is plenty of hazardous energy, we get used to it pretty quickly. And as soon as the fear or skill is no longer pre-occupying, your mind can wander. We don’t give our minds permission for this, it happens as soon as our subconscious determines we’ve “got it.” So we can’t really stop complacency from leading to mind not on task. But as mentioned before, we can find ways to bring our mind back on task quickly and efficiently. And that’s where the third critical error reduction technique comes in.

Fighting complacency

As soon as things become too familiar, they tend to get “filtered out” by a part of your brain called the Reticular Activation System or RAS. Its purpose is to filter out the “noise” in the environment, such as the birds in the trees so you can instead hear the rustle in the grass and know it could be a snake. And while this might have been a really good thing dozens of years ago, it isn’t much help for things like driving at highway speed and trying to remain vigilant.

So we talked about habits like leaving a safe following distance when driving to help compensate for complacency, leading to mind not on task. But if you’re driving and you happen to see someone following way too close, you will find yourself almost automatically checking your own following distance as well. So, taking this idea a bit further, if we observe others for state to error risk patterns, every time we see one, we will think about risk, which will make us think about ourselves and the risk of what we are doing.

And if we practice looking for these state to error risk patterns enough, it’s like training our RAS to “light up” whenever we see one. So the RAS isn’t all bad, because you can also train your RAS to see or find what you want to pick out of the noise.

Unfortunately, some people only use this “talent” to be able to find liquor stores or their favorite hamburger joint. And they can do this much faster than others who have not trained their RAS to look for those “important” things.

You can try it yourself: just look for anything you see that’s red before you leave the house. Say what it is out loud as you see each thing or item. Now pay attention to how many red cars you notice when you start driving (there’s lots). So provided you make a bit of an effort, you can train your RAS to look for risk patterns. And once you start to see them, you’ll see them everywhere. And it will really help to keep your eyes and mind on task. Or, to put it another way, this CERT will help you fight complacency.

Analyzing small errors

The last CERT we need to cover is, “Analyze close calls and small errors” so you don’t have to agonize over the big ones. The basic principle here is that there are so many little injuries or close calls compared to serious injuries. But they’re all caused by the same state to error risk pattern.

If we could learn from the “free” ones we wouldn’t have to agonize over the serious ones. So, whenever you make a mistake, bump into something, or momentarily lose your balance — even if you don’t fall down — ask yourself why. Was it a state like rushing, frustration or fatigue that you didn’t self-trigger on; was it complacency leading to mind not on task.

If it was complacency, then you probably need to work on improving a safety-related habit, or you might need to put more effort into observing others for state to error risk patterns. So that’s the basic or the fundamental part of this technique. But another part of this technique is to think about how this close call or minimal injury could have been worse.

By contemplating the worst-case scenarios, more and stronger neural pathways are created in our brains, which eventually will give us that almost instant sense of danger. So getting people to tell stories about injuries and serious close calls that have happened to them, the states and critical errors involved, and then getting them to think about how it could’ve been worse isn’t fear mongering. It’s actually just using the neuroscience to our advantage.

Using your imagination

Instead of always having to experience the pain ourselves, we can think about it when we hear stories from other people, and that works almost as well. Did you know you could use your imagination to help prevent serious injuries? (My dad didn’t.) And as you can imagine, it’s a fairly big shift for a lot of managers and safety professionals who can’t understand why we’re wasting time getting employees to tell stories about their serious accidental injuries and the pain/inconvenience they caused. These are usually the same folks who are still back at the “hazards and sunk costs” paradigm. So, for them, there is some good news because using your imagination doesn’t cost any money.

In summary, there are four critical error reduction techniques to deal with the injuries in the Self-Area (over 95 percent). These techniques are supported by neuroscience, which proves, among other things, why you have to put some time and effort into the four CERTs. Just like the path through the grass field, a lot of repetition is the key to making the neural pathway in the first place, and a certain amount of repetition is also required to maintain the pathway so it doesn’t erode or fade away.

Just like with a musical instrument that you haven’t played in a while or a language you haven’t spoken in a long time, those pathways will also get weaker if you don’t keep using them. So we can learn a lot from the neuroscience. Especially as it relates to complacency, habits and how enough rushing and frustration can override even good habits.


Washington — New guidance from OSHA answers six frequently asked questions regarding the use of masks in the workplace during the ongoing COVID-19 pandemic.

Among the agency’s answers is an explanation of the key differences between cloth facial coverings, surgical masks and respirators. Other topics include whether employers are required to provide masks, the continued need to follow physical distancing guidelines when wearing masks and how workers can keep cloth masks clean.

“As our economy reopens for business, millions of Americans will be wearing masks in their workplace for the first time,” acting OSHA administrator Loren Sweatt said in a June 10 press release. “OSHA is ready to help workers and employers understand how to properly use masks so they can stay safe and healthy in the workplace.”

The agency reminds employers not to use surgical masks or cloth facial coverings for work that requires a respirator.


Two weeks ago, OSHA revised its policy, saying it will expand inspections beyond those in healthcare facilities, which the agency said last month it was prioritizing to conserve resources.

OSHA’s announcement stated that the agency would:

● Increase in-person inspections at all types of workplaces. This is in response to the fact that many non-essential businesses have begun to reopen in areas of lower community spread.
● Revise its previous enforcement policy for recording cases of coronavirus. Under OSHA’s recordkeeping requirements, coronavirus is a recordable illness, and employers are responsible for recording cases of the coronavirus, if the case:

1. is confirmed as a coronavirus illness;
2. is work-related as defined by 29 CFR 1904.5; and
3. involves one or more of the general recording criteria in 29 CFR 1904.7

Following the listed requirements for recordkeeping, OSHA added, “given the nature of the disease and community spread, however, in many instances it remains difficult to determine whether a coronavirus illness is work-related, especially when an employee has experienced potential exposure both in and out of the workplace.”

OSHA can fine employers for violating workplace safety rules, but only after it conducts inspections and investigations.

In a notice on April 10, OSHA said it would consider “good faith” efforts of employers to protect employees before issuing citations. This meant it would “exercise enforcement discretion” because of the difficulty of proving how or where a worker contracted the SARS-CoV-2 virus.

While the revisions expand OSHA’s power in holding employer accountable for coronavirus safety, many say the revisions stop short of one of the key demands of worker unions: that OSHA adopt an emergency temporary standard for workplace safety regarding COVID-19.

In fact, the American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) (the largest federation of labor unions) has been urging the agency to adopt an infectious disease standard since 2009, according to one article.

A COVID-19 standard would impose requirements on businesses and speed up the enforcement process for companies that don’t comply, said David Muraskin of advocacy group Public Justice.

He says that the general clause for employers to protect their employees in a safe workplace is not enough, since its requirements are softened by language like “where possible” and “where feasible.”

“That’s why people want actual standards,” said Muraskin. “It has a real effect. These inspections are likely a way for the administration to claim it is doing something without actually doing anything.”

To date, OSHA has not issued any citations for COVID-19 related inspections. “But out of more than 3,800 Covid-19 related complaints that OSHA has received—many concerning a lack of personal protective equipment such as face masks, gloves and gowns—the agency had opened only 281 coronavirus-related inspections as of May 13,” according to a Labor Department spokesperson.


Before COVID-19, the acronym PPE was not known by most people. Industrial workers, first responders, and healthcare workers are familiar with Personal Protective Equipment (PPE) because they use it every day. However, on an ordinary day, using the PPE acronym in a conversation, usually required some sort of explanation:

“Well, you know, PPE are safety products that protect people when they’re working… like gloves, goggles, hard hats, and face masks.”

Because of COVID-19, you don’t have to explain PPE anymore. This novel coronavirus has catapulted the acronym into the mainstream vernacular, shop talk and watercooler banter.

During this pandemic, healthcare workers and others have been scrambling for two sought-after products in the PPE pandemic world: the N95 respirator and surgical face masks. According to a survey conducted by Premier, Inc.,1 a healthcare improvement company, “Hospitals ranked the supply of N95 respirators as their top concern. . . . In addition, the availability of PPE and burn rates for PPE products were the two most commonly cited ‘surprises’ of the pandemic.”

The mayhem and fear surrounding the shortage of these items created misinformation and myths. Below we will explore five protection myths about N95 respirators, surgical face masks, and face coverings.

Myth #1: The N95 respirator and a surgical face mask are basically the same thing, offering very similar protection.

They are not the same thing and provide different types of protection. Although they serve different purposes, on March 10, the CDC updated its recommendations and advised that face masks for clinical providers are an acceptable alternative2 when there is a shortage of N95 respirators. But it is important to understand the differences between the two.

The N95 Filtering Facepiece Respirator (FFR)

Although the N95 respirator is frequently called a mask, it is a Filtering Facepiece Respirator (FFR) designed to reduce inhalation exposure to particulate contaminants, which are microscopic particles of solid or liquid matter suspended in the air.

In the industrial work force, N95 respirators are commonly used to decrease exposure to wood dust, animal dander, mold, and pollen. During the COVID-19 pandemic, healthcare facilities have been using N95 respirators — when they can get their hands on them — in their infection control programs.

The N95 respirator is tight-fitting and creates a seal on the face, whereas a face mask has gaps on the sides where particles or infectious agents can enter. The fit of a N95 respirator is so important that use of one requires annual fit-testing to ensure the wearer receives the intended 95 percent filtering of particles with mass median diameter of 0.3 micrometers. However, OSHA has temporarily suspended3 the fit-test rule during COVID-19.

The N95 includes a specialized filter that captures at least 95 percent of the airborne particles that pass through it, but it is not resistant to oil. The N95 is evaluated, tested, and approved by NIOSH as per the requirements in 42 CFR Part 84.

The surgical N95 respirator (N95s)

There is a subset of the N95 respirator worn by healthcare workers to protect the patient and themselves from the transfer of body fluids, microorganisms, and particulate airborne matter. This subset is called the surgical N95 respirator (N95s). According to the CDC, a surgical N95 respirator “is a NIOSH-approved N95 respirator that has also been cleared by the FDA as a surgical mask.” The surgical N95 respirator is like a hybrid. It is a filtering facepiece respirator with the added benefit of splash-resistant face mask material on the outside.

According to OSHA, “respirators offer the best protection for workers who must work closely (either in contact with or within 6 feet) with people who have influenza‑like symptoms.” Therefore, they should be reserved for workers who work in occupations with high exposure to pandemic influenza or COVID-19.

Respirators are considered single-use PPE and should be discarded, placed in a plastic bag, and disposed of properly when:

● They become damaged or lose their shape
● They no longer form an effective seal to the face
● They become wet or visibly dirty
● Breathing becomes more difficult because the filter is clogged with particles
● They become contaminated with blood, nasal secretions, or patient body fluids

Approved reuse of N95 Respirators via Vaporized Hydrogen Peroxide sterilizers

Normally, the N95 respirator is considered a disposable, single use PPE item. However, on April 10th, the U.S. Food and Drug Administration announced the second emergency use authorization (EUA) to decontaminate compatible N95 or N95-equivalent respirators for reuse by health care workers in hospital settings. This EUA will support decontamination of approximately 750,000 N95 respirators per day in the U.S.

“This EUA is another game changer,” said FDA Commissioner Stephen M. Hahn, M.D. “It will allow hospitals to decontaminate compatible N95 respirators using vaporized hydrogen peroxide sterilizers that are readily available in approximately 2,000 U.S. hospitals. It’s another important step forward in helping to reduce shortages in critical N95 respirators, by allowing for these important devices, when decontaminated, to be reused by health care personnel on the front lines of the COVID-19 pandemic.”

The surgical, medical, or procedure mask (face masks)

Regulated under 21 CFR 878.4040, a surgical mask is often referred to as a “face mask.” It is primarily intended to protect against saliva and respiratory secretions.

Unlike the N95, a surgical mask does not form an adequate seal to the wearer’s face, so healthcare workers cannot rely upon it to protect against airborne infectious agents. Nor does it require an annual fit-test and seal-check that is usually typical of the N95 respirator.

A surgical mask is fluid resistant and provides a physical barrier to protect the user from large droplets or splashes of blood or body fluids. It does not block or filter small particle aerosols from coughs or sneezes. Not regulated for particulate filtration, it may be labeled as a surgical, isolation, dental, or medical procedure mask. It is cleared by the U.S. Food and Drug Administration.

Surgical masks should be discarded after one patient encounter according to medical facility rules and regulations.

The CDC has a helpful infographic4 that explains the differences between the N95 respirator and the surgical face mask. It makes a great handout for training.

Myth #2: N95 respirators with exhalation valves can be used when trying to maintain a sterile environment in an operating or procedure room.

N95 respirators can be purchased with or without exhalation valves. Exhalation valves are a critical component of industrial respirators. They are designed to permit minimal inward leakage of air contaminants during inhalation and provide low resistance during exhalation.

Despite the comfort benefits of an exhalation valve for industrial workers, N95 respirators with exhalation valves should not be used when trying to maintain a sterile environment in an operating room. Although the exhalation valve makes breathing easier, any bacteria or virus expelled from the user may travel through the exhalation valve and enter the operating room, compromising the sterile environment.

Myth #3: If a health care worker is properly wearing a surgical face mask, he or she is adequately protected from inhaling airborne infectious agents, including those from a patient who is exhaling, coughing, or sneezing.

This is not true of a surgical face mask. However, it is true of N95 respirators and surgical N95 respirators. The CDC says, “If properly fitted, the filtration capabilities of N95 respirators exceed those of face masks.”

Surgical face masks do not provide protection from small particles, like airborne infectious agents. However, they trap large particles of body fluids that may contain viruses or bacteria keeping contaminated larger droplets from reaching the nose and mouth. Remember, a surgical mask does not form an adequate seal to the wearer’s face, so it cannot be relied upon for complete protection.

Myth #4: It’s OK to touch the inside and outside of your mask or respirator when putting it on or taking it off.

Just like you should avoid touching your face to help prevent contamination, you should not touch the inside or outside of a face mask or N95 respirator. With clean, sanitized hands, you should always pick up or take off the mask by its straps, ear loops, or ties. Always wash your hands or use alcohol-based hand sanitizer before and after mask/ respirator removal and be conscious that the outside of the mask is a contamination zone.

For purchased masks or respirators, always follow product instructions on use, disposal, and storage (when applicable) and follow the procedures for mask donning and removal.

Myth #5: Wearing a face covering or cloth mask in public will protect the wearer from getting infected by others.

Unfortunately, this is not true. According to the CDC, textile (cloth) masks “are not PPE, and it is uncertain whether cloth face coverings protect the wearer.”

Made-at-home face coverings or cloth masks are not a preventative measure you can take to avoid getting a highly contagious virus like COVID-19. However, wearing a cloth mask in public, like at the grocery store, will help prevent the spread of the disease to others. COVID-19 doesn’t always present symptoms, so wearing masks in public is usually a healthy thing to do, but it shouldn’t give people a false sense of protection.

Lessons learned

Hopefully, America and the world will be back at work soon, rebuilding our economy and the livelihoods so profoundly affected by this tiny but destructive virus. Although we did not know much about this novel coronavirus in the beginning, we are much smarter now. May the lessons we learned during COVID-19 carry us forward to create a safer and healthier world. By all means, let’s remember the importance of PPE and take steps to ensure our supply chains and distribution centers are well positioned to protect those who protect us.


The Centers for Disease Control and Prevention (CDC) has issued guidance aimed at state governments and employers about the reopening of workplaces and other sites to the public earlier ordered closed in response to the Coronavirus pandemic.

The 62-page document details how the agency is supporting the step-by-step reopening of the nation’s economy and offers practical advice for employers and employees, much of which is in line with earlier recommendations issued over the past three months by the CDC, other federal agencies, state and local governments, and industry associations.

The publication also offers interim guidance aimed at childcare programs, schools and day camps, employers with high-risk workers, restaurants and bars, and mass transit administrators.

“As businesses and other organizations gradually open after the COVID-19-related slowdown, they will need to consider a variety of measures for keeping people safe,” CDC says. “These considerations include practices for scaling up operations, safety actions (e.g., cleaning and disinfection, social distancing), monitoring possible re-emergence of illness, and maintaining health operations.“

Critics of the Administration had faulted President Trump for encouraging states to begin reopening businesses before the CDC had a chance to weigh in with its recommendations on how they should proceed, which are embodied in the guidance that was published on May 26. Many states already had forged ahead with their own reopening plans after obtaining input and advice from a variety of sources.

In addition, other federal and state agencies had adopted other CDC guidelines when they were in the process of developing recommendations for employers who continued to operate during the quarantine as essential businesses and operations, like emergency and medical services. Many of those guidelines appear to have been incorporated into current state reopening plans.

The agency recommends a three-phased plan for reopening that outlines an approach for relaxing community mitigation measures while protecting vulnerable populations, such as the elderly and those with underlying health conditions. Along with the three-phased approach, the CDC proposes the use of six “gating criteria” to be assessed before progressing into the next phase of reopening.

This approach can be implemented statewide or community-by-community at each state governor’s discretion, according to the CDC.

These gating criteria include decreases in newly identified COVID-19 cases, decreases in emergency department and/or outpatient visits for COVID-19-like illness, and the existence of minimum infrastructure necessary for a robust testing program.

As an example, to enter Phase 1 of reopening, a community would assess the gating criteria of decreases in newly identified cases and would need to determine whether there is a downward trajectory (or near-zero incidence) of documented cases over a 14-day period.

Consideration between phases should be given to such factors as existing public health capacity based on certain measurable criteria, such as contact tracing and incidence relative to local public health resources, notes the law firm of Greenberg Traurig LLP.

“The guidance acknowledges some communities may progress sequentially through the reopening phases while other jurisdictions may end up moving backwards at certain points, based on an ongoing assessment of the gating criteria against the threshold for entering each phase,” it says.

Where Employers Fit

When it comes to state and local supervision of the reopening of different businesses the CDC recommends the imposition of a three-step process for scaling up. These steps are scaling up for businesses only if they can ensure:

Step 1: Strict social distancing, proper cleaning and disinfecting requirements, and protection of their workers and customers; workers at higher risk for severe illness are recommended to shelter in place.

Step 2: Moderate social distancing, proper cleaning and disinfecting requirements, and protection of their workers and customers; workers at higher risk for severe illness are recommended to shelter in place.

Step 3: Limited social distancing, proper cleaning and disinfecting requirements, and protection of their workers and customers.

For individual workplaces that begin to scale up activities towards pre-COVID-19 operating practices, CDC acknowledges that some workers are at higher risk for COVID-19. These include workers over age 65 and those with underlying medical conditions, such as chronic lung disease, hypertension, weakened immunity, or severe obesity.

Workers at higher risk for severe illness should be encouraged to self-identify, and employers should avoid making unnecessary medical inquiries, stress attorneys Thomas Gies, Thomas Koegel, Kris Meade and Tyler Brown of the Crowell & Moring law firm.

“Employers should consider carefully how to reduce workers’ risk of exposure to COVID-19 consistent with relevant Americans with Disabilities Act (ADA) and Age Discrimination in Employment Act (ADEA) regulations and guidance previously issued by the Equal Employment Opportunity Commission (EEOC),” they add.

To protect higher risk employees, CDC suggests that, throughout all three of the reopening steps, employers should consider various solutions, such as:

● Supporting and encouraging options to telework.
● Offering workers at higher risk duties that minimize their contact with customers and other employees (e.g., restocking shelves rather than working as a cashier), if agreed to by the worker.
● Encouraging contractors and other entities sharing the same work space to follow CDC guidance.
● Attempting to reduce potential community spread by adopting steps to eliminate travel by employees to workplaces in lower transmission areas and vice versa.

The suggested best practices for employers can vary depending on the numbered step adopted by their state government. The CDC points out, “the scope and nature of community mitigation suggested decreases from Step 1 to Step 3” but ultimately, “some amount of community mitigation is necessary across all steps until a vaccine or therapeutic drug becomes widely available.”

Most employers have heard of the CDC’s recommended best practices, which cover among other things promoting healthy hygiene practices; intensifying cleaning, disinfection and ventilation; promoting social distancing; limiting sharing; and training all staff. Also included are checking for signs and symptoms; planning for what to do when employees get sick; and how to maintain healthy operations.

Attorneys Lori Armstrong Halber and Leora Grushka of the Reed Smith law firm urge that businesses operating “typical” workplaces (meaning they are not childcare, schools, restaurants/bars, or mass transit) should also consider the following key takeaways:

● Continue to implement social distancing through all three reopening steps. Businesses operating in-person services should stagger or rotate shifts whenever possible and consider video- or tele-conference calls over in-person meetings.
● Limit group gatherings to no more than 10 people during Step 1 and no more than 50 people during Step 2. Throughout all of the steps, gatherings should not take place if a distance of six feet cannot be maintained between participants.
● Consider conducting routine, daily health checks or temperature and symptom screening of all employees and encourage all sick employees to stay home. Send employees with symptoms home immediately and have procedures in place to disinfect, notify local authorities and inform employees who may have been in close contact with the sick employee.

Halber and Leora Grushka also recommend that employers should create and maintain a system to encourage their employees to self-report and notify management about any exposure they may have experienced.

“Remember the effect the pandemic may be having on employees and implement flexible practices, including flexible sick leave and telework policies,” they stress. “Additionally, businesses should appoint an individual as a point of contact to respond to COVID-19 concerns and monitor absenteeism.”

The Crowell & Moring lawyers note this new CDC guidance is meant to complement the agency’s previously released decision tools, such as the Workplace Decision Tool, as well as other COVID-19-related Occupational Safety and Health Administration (OSHA) and CDC guidance. CDC will continue to update this guidance as it develops further best practices.


The agency said they would allow more impurities in alcohol-based hand sanitizer.

In a statement from the Food and Drug Administration, the federal government announced it would relax regulations on impurities in alcohol-based hand sanitizer. The move, announced today by FDA Commissioner Stephen M. Hahn, M.D., is intended to “help ensure widespread access to hand sanitizers during the COVID-19 public health emergency.”

According to the FDA, the agency previously updated its restrictions in April in response to requests from fuel ethanol manufacturers, who had pivoted their supply chains to produce hand sanitizer instead of fuel.

The FDA’s statement said that data produced by those manufacturers showed their fuel ethanol products contained gasoline and benzene, which it said were known carcinogens. The updated guidance allows hand sanitizer to include up to 2 parts per million of benzene.

The coronavirus pandemic has stretched supply chains around the world to the breaking point by playing havoc with the economies and industrial sectors of entire countries. Now, even as the United States has reopened most of its factories, sharp demand for products required to maintain stricter cleanliness standards has put suppliers under strain. The Institute of Supply Managers listed hand sanitizer and a variety of PPE as supplies in notably short supply during May.

The FDA recommends use of hand sanitizer containing at least 60% alcohol as a substitute for washing with ordinary soap and water, and hand sanitizer stations for workers to regularly clean their hands at have become a common feature of reopened factories invested in keeping workers healthy.

While many manufacturers of durable goods have repurposed supply chains to producing face shields, masks, gloves, gowns, and similar products, alcohol-based hand sanitizer has proven a popular COVID-19 relief product for chemical companies and brewers to manufacture at scale. Dow Chemical Co., Ineos, and small distilleries all around the world have turned their stocks of chemical alcohol and chemistry equipment into supply lines for the cleaning agent.


Washington — Aimed at reducing COVID-19 exposure among construction workers, OSHA has created a new website with guidance for employers.

The website includes a table that describes work tasks and their exposure risk level (from “very high” to “lower”), based on the agency’s occupational risk pyramid for COVID-19. The website also covers engineering and administrative controls, safe work practices, and personal protective equipment. In the administrative controls section are screening questions employers should ask before sending workers into “an indoor environment that may be occupied by a homeowner, customer, worker or another occupant,” and recommended actions based on the answers to those questions.

The website also has a section on cloth face coverings. OSHA warns that “cloth face coverings are not PPE. They are not appropriate substitutes for PPE such as respirators (like N95 respirators) or medical facemasks (like surgical masks) in workplaces where respirators or facemasks are recommended or required to protect the wearer.”

Other recommendations:

• Keep in-person meetings such as toolbox talks as short as possible, limit the number of workers in attendance and keep everyone at least 6 feet apart during the meetings.
• Make sure shared spaces in home environments have proper airflow.
• Stagger work schedules, such as alternating workdays or extra shifts, to reduce the number of employees on a jobsite at one time.

“Employers of workers engaged in construction (such as carpentry, ironworking, plumbing, electrical, heating/air conditioning/ventilation, utility construction work, and earth-moving activities) should remain alert to changing outbreak conditions, including as they relate to community spread of the virus and testing availability,” OSHA states in a May 26 press release. “In response to changing conditions, employers should implement coronavirus infection prevention measures accordingly.”


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