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Aerosol Transmissible Diseases - Exposure Control Plan
Cal/OSHA adopted a new standard, CCR T8 § 5199 effective August 5, 2009 regulating employee exposure to aerosol transmissible diseases (ATDs). These diseases can be spread through the air in the form of small particles or droplets. Influenza, tuberculosis, and severe acute respiratory syndrome (SARS) are a few examples of aerosol transmissible diseases. Please also see these other Loss Control Bulletins: Aerosol Transmissible Diseases –Referring Employers, Aerosol Transmissible Diseases – Laboratories, and Aerosol Transmissible Diseases – Summary.
| An Aerosol Transmissible Disease (ATD) or Aerosol Transmissible Pathogen (ATP) is a disease or pathogen for which droplet or airborne precautions are recommended. These are listed in Appendix A of the standard CCR T8 5199. |
WHO NEEDS TO WRITE AN ATD EXPOSURE CONTROL PLAN (ECP) PER CCR T8 § 5199 (D)?
- Any facility, service or operation that houses, or provides care or management to airborne infectious disease cases needs an ECP unless they are a Referring Employer as defined in the standard.
- Any facility that performs High Hazard Procedures
Any of the following could need an ECP:
- Hospitals
- Skilled nursing facilities
- Clinics, medical offices, and other outpatient medical facilities
- Home health care
- Long term health care facilities and hospices
- Medical outreach services
- Paramedic and emergency medical services including these services when provided by firefighters and other emergency responders
- Outpatient facilities
- Certain public health services
The following will definitely need an ECP:
- Facilities, services or operations that perform aerosol-generating procedures on cadavers such as pathology laboratories, medical examiners’ facilities, coroners’ offices, and mortuaries
- Medical transport
- Correctional facilities that keep TB patients in airborne infection isolation cells
- Facilities, services, or operations that are designated to receive persons arriving from the scene of an uncontrolled release of hazardous substances involving biological agents
- Police Services provided during transport or detention of persons suspected to be cases of ATDs and police services performed in conjunction with public health operations
| High Hazard Procedures (HHPs) are performed on a person who has a case or suspected case of an ATD or a specimen suspected of containing an Aerosol Transmissible Pathogen – Laboratory (ATP-L) [A list of these can be found in Appendix D of 8 CCR § 5199], in which the potential for being exposed to aerosol transmissible pathogens is increased due to the generation of aerosolized pathogens. |
HHPs include, but are not limited to
- Sputum induction
- Bronchoscopy
- Administration of aerosolized pentamidine or other medications
- Pulmonary function testing
- Autopsy
- Clinical, surgical and laboratory procedures that may aerosolize pathogens
As of September 1, 2010, high hazard procedures with possible ATD exposure must be done by employees wearing a powered air-purifying respirator (PAPR) with a High Efficiency Particulate Air (HEPA) filter(s), or a respirator that provides equivalent or greater protection unless there are effective engineering controls. There is an exception to the PAPR requirement when the employer determines that the use of a PAPR would interfere with the procedure being performed. The justification for the exception must be documented in writing. Paramedics and EMTs may use a P100 respirator. When respirators are required, the employer must establish and implement a written respiratory protection program in accordance with T8 CCR § 5144 Respiratory Protection. (In some instances, an alternate medical questionnaire to the one in Section 5144 can be used).
Aerosol Transmissible Disease Exposure Control Plan
The ATD Exposure Control Plan must be specific to the operation or task and must document the following elements:
- Designation of a Program Administrator by name or title who is knowledgeable in infection control procedures and facility practices
- Determination of which job classifications have occupational exposure
- Determination of which high hazard procedures are performed
- Determination of which assignments, tasks or procedures will need controls for prevention of transmission of ATDs. These controls could be engineering controls, work practice controls or respiratory protection.
- For each task, operation or work area where occupational exposure occurs, the following must be designated:
- Specifics of required engineering, work practice, or other controls
- Specific cleaning and decontamination procedures
- Specific source control methods, such as Respiratory Hygiene / Cough Etiquette, and the means for informing people entering the workplace of the requirement
- Specifics of personal protective equipment (PPE) requirements
- Cal/OSHA compliant written programs to support the provision of PPE, such as CCR T8 5144 Respiratory Protection
Airborne Infectious Disease Cases (AirID cases) are either
An aerosol transmissible disease, transmitted by airborne droplet nuclei, small particles, or dust particles containing the disease agent for which the Centers for Disease Control and Prevention (CDC) or the California Department of Public Health (CDPH) recommends airborne infection isolation, or
An unknown pathogen where droplet or airborne transmissibility has not been ruled out.
Airborne infection isolation (AII) describes infection control procedures as described in Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings. These procedures are designed to reduce the transmission of airborne infectious pathogens.
Airborne infection isolation room or area (AIIR). A room, area, booth, tent, or other enclosure that is maintained at negative pressure to adjacent areas in order to control the spread of airborne infectious pathogens and that meets the requirements stated in subsection (e)(5)(D) of the standard. |
- The procedure for early identification and procedures to temporarily isolate, and refer or transfer AirID cases or suspected cases to AII rooms, areas or facilities. These procedures must include:
- Means to limit employees’ exposure when the patients are not in AII
- Methods the employer will use to document medical decisions about not transferring these patients to airborne isolation
- Establishing AIIRs, daily ventilation tests, and decontamination procedures
- Specific means of implementing medical services such as vaccinations and follow-up
- In the case of an exposure incident the employer must develop:
- A method to determine an exposure to a reportable ATD of an individual who has been exposed to a person, or a work area or equipment that contained ATPs where the individual(s) were not protected by exposure controls
- A method for investigation and prevention of similar incidents
- A procedure for communicating with employees and others (including facilities personnel) regarding the suspected or confirmed reportable disease status of persons to whom employees may have been exposed in the course of their duties
- A procedure for communicating with other employers about exposure incidents including procedures for providing or receiving information on the disease status of persons that have been referred or transferred
- Follow-up, which may require medical removal (paying an employee their regular pay while they have been told to stay off work by a physician or other licensed health care worker to prevent the employee from spreading a communicable disease)
- Steps the employer will take to ensure there is an adequate supply of personal protective equipment in normal operations and in possible emergencies
- Specific procedures for initial and annual training of exposed employees on the ECP and infection control procedures
- Maintaining appropriate records and having them available for inspection by Cal/OSHA and others
- Surge Procedures (procedures to meet increased demand caused by disasters or other emergencies)
- Reviewing the program annually and correcting deficiencies. Review procedures must incorporate input from affected employees
The above evaluations and/or recommendations are for general guidance only and should not be relied
upon for legal compliance purposes. They are based solely on the information provided to us and relate
only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
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