Pandemic flu

Scope

According to the World Health Organization (WHO), once a human pandemic begins, it is expected to encircle the globe within three months. Because the virus would be a new strain, the majority of the population would have no protection against it. While the race would be on to manufacture and stockpile antiviral drugs, worldwide availability is low, and there is evidence that influenza viruses can be resistant to this treatment.

Regulatory citations

• 29 CFR 1910 Subpart I — Personal protective equipment
• 29 USC 654 — Duties of employers and employees (including Pub. L. 91–596 “OSH Act of 1970” 5(a)(1), the “General Duty Clause”)

Key definitions

• Pandemic influenza (flu): A global outbreak of a new influenza A virus. According to the Centers for Diseases Control and Prevention (CDC), pandemics occur when new influenza A viruses emerge that are able to infect people easily and spread from person to person in an efficient and sustained way.
• Seasonal influenza: The periodic outbreaks of respiratory illness in the fall and winter in the United States. These outbreaks are typically limited. Most people have some immunity to the circulating strain of the virus.

Summary of requirements

While there are no regulatory requirements tied directly to pandemic flu, employers may use a combination of control measures to protect employees and customers:

• Engineering controls are those that involve making changes to the work environment to reduce work-related hazards. Examples include:
  • Installing sneeze guards,
  • Installing drive-through windows, and
  • In some limited healthcare settings, using specialized negative-pressure ventilation.
• Administrative controls are those that modify workers’ work schedules and tasks in ways that minimize exposure to workplace hazards. Examples include policies that:
  • Encourage ill employees to stay home;
  • Allowing or encouraging remote work;
  • Discontinue unessential travel;
  • Encourage non-face-to-face communication methods like phone, email, internal websites, and teleconferences; and
  • Use home delivery instead of customer visits to the business.
• Safe work practices are procedures for safe and healthy work that are used to reduce the duration, frequency, or intensity of exposure to a hazard. Be sure to provide facial tissue, no-touch trash containers, hand soap, hand sanitizer, disinfectants, and disposable wipes in a pandemic. Safe work practice examples include:
  • Washing hands frequently or with hand sanitizer where soap and water is not available,
  • Practicing cough/sneeze etiquette,
  • Practicing social distancing (maintaining a six-foot distance),
  • Cleaning and sanitizing work surfaces and equipment,
  • Not sharing tools and equipment, and
  • Holding meetings over the phone or online instead of in-person.
• Personal protective equipment (PPE) is protective gear required to keep workers safe while performing their jobs. (See 29 CFR 1910 Subpart I.) Examples of PPE include respirators, face shields, goggles, and disposable gloves. The appropriate types of PPE for use during a pandemic will be based on the risk of contracting influenza while working and the availability of PPE.
• Surgical masks are used to protect workers against splashes and sprays (i.e., droplets) containing potentially infectious materials, so in this capacity, surgical masks are considered PPE. However, surgical masks are not respirators and may not be used when respirators are required. In addition, the employer may allow the voluntary use of surgical masks and may provide surgical masks for voluntary use.
• Cloth face coverings are not PPE but may be better than no mask at all. Masks are made to contain droplets and particles an employee breathes, coughs, or sneezes out. Loosely woven cloth products provide the least protection, while layered finely woven products offer more protection.

To reduce the impact of a pandemic on your operations, employees, customers, and the general public, it is also important (but not required) for all businesses and organizations to develop some kind of pandemic flu preparedness plan.