Employers and healthcare assessment providers need to be fully informed of the guidelines and protocols that govern employee fit testing and vaccinations two procedures necessary to meet regulatory compliance with OSHA and have to be administered properly to keep both workers and their companies protected. Also, their proper implementation and documentation are important to protect assessors from undue liability.
Throughout NAOHP’s interactions with occupational health professionals from around the country, many similar questions and concerns come up regarding fit testing and vaccinations. Fortunately, OSHA’s outlines of the two procedures are well-defined. We’ve compiled some best practices to follow as defined by OSHA and have detailed them for you here.
Fit Testing for Employee Respirator Use
The best resource for fit testing documentation and guidelines is available on OSHA.gov under the heading “1910.134
App A – Fit Testing Procedures (Mandatory).” It lists all of the requirements for the assessment of employees who are to wear a respirator. For a direct link, take note of our sidebar section listed on this page.”
What regulations govern fit testing?
• An employer’s policies and procedures are required to determine the need for fit testing.
• An occupational health program(OHP) medical director sets protocols for all fit testing to be done within an employer’s program.
• Management must set competencies for who does the fit testing.
• The manufacturer of the respirators and/or mask sets the specific fit requirements.
What competencies are required to provide these services?
Manufacturers have training programs for fit testing for their masks/respirators. “Train the trainer” programs are available, industrial programs can identify the individuals who’ll be conducting training and develop an internal trainer for all staff.
Employee Vaccination Requirements
Vaccinations, of varying types, are required for employees that work in many different industries, not simply just in healthcare. Understandably, some of the more specific vaccinations apply to healthcare and other medical care employees, but housekeepers, dishwashers, nursing home employees, first aid responders, school nurses, emergency responders, and others all require vaccinations too.
What vaccinations may be required?
• The CDC recommends Hepatitis B immunizations. If an individual starts the vaccination series, it is important to finish the series, which is conducted as follows: first dose, then the second dose in one month, and the third five months after the second.
• Many states have mandates for flu vaccines. Some health systems require employees who don’t have flu immunizations to wear masks during the flu season. The Total Health Management Model Reinforces onsite immunizations for client company employees.
• The MMR (Measles, Mumps, rubella) vaccine is required for several career fields. According to the CDC, one dose of the MMR vaccine should be adequate protection for those born during or after 1957 who lack a history of mumps. Individuals in other age groups may require an additional dose.
• The Varicella vaccine will require two doses if the individual has no immunization or no history of chickenpox.
• A booster of the Tdap vaccine(Tetanus, Diphtheria, Pertussis) is typically required every 10 years.
• Additional information can be found here: www.cdc.gov/vaccines/adults/rec-vac/hcw.html
How can you provide vaccinations when the shelf life of some is very short?
Careful stocking and scheduling of appointments can provide for drug ordering several days before administration.
What role does the medical director have in identifying what vaccinations are given to whom?
The medical director is responsible for the provision of clinical services. This identifies the medical director as the individual who sets the standards and competencies necessary for the services.
Documentation and Templates
Proper documentation of vaccinations and fit testing outcomes is essential to protect not only employers and occupational health professionals from incident liability, but also to receive the proper authorization for an employee to proceed to work across numerous job sites and work environments.
How do you document the services for these two procedures?
• Templates are available for specific fit-testing processes here: https://www.osha.gov/video/respiratory-protection/fit-testing/transcript
• Templates are also available for vaccination documentation, immunization teaching, obtaining informed consent, and other questions. It’s important to provide a listing of the serial numbers, dates, and locations where the injection was placed. The schedule needs to be clearly defined, and the employee and the employer need to be notified of the dates for return immunizations.
Stay Informed to Ensure Compliance
Companies and healthcare professionals need to stay informed of these protocols to ensure their operations are in full compliance with OSHA and the requirements of outside vendors, project owners, clients, etc.
As always, NAOHP and Ryan Associates Are here to support your organization with any questions you may have. Don’t hesitate to reach out to us.
