Jill:

This is The Accidental Safety Pro brought to you by Vivid Learning Systems and The Health and Safety Institute. This is a special edition of the podcast and was recorded on June 18th 2020. My name is Jill James, The Health and Safety Institute's Chief Safety Officer. Today I'm joined by my friend and now perennial favorite to the podcast, Mark Catlin. Mark has been a guest for episode 11 and also our Special Dedication Episode to Dr. Eula Bingham. Mark is an Industrial Hygienist with MDC Consulting and Training in Maryland. Like many, Mark has been on the front lines throughout this pandemic, utilizing his talent, training and expertise to protect essential workers. I've asked Mark here today to talk about what he's been up to these past months, so welcome back, Mark.

Mark:

Thank you, Jill. It's good to be here.

Jill:

Yeah. Pandemic, industrial hygienist, the work that you've been doing for... your life's work for now what? Are you in your... How many years have you been at this Mark?

Mark:

Almost 40 years.

Jill:

Almost 40 years?

Mark:

Yeah.

Jill:

Yeah. What has this pandemic been like for your career? What have you been up to?

Mark:

Well, I was semi-retired and doing some consulting work over the past 18 months and this is consulting work that I had scheduled to do in 2020, just simply vanished, like for many other folks, because you can't go on site anymore. We can't go out and do things in person. What it's been replaced with is actually a lot of assistance to folks who are working on the front lines with, mostly in healthcare with other areas and doing it via conference call and Zoom and email. The work has really changed. I stay isolated in my home because I'm in the high risk categories for COVID-19 and so I'm staying isolated, but happy to be able to do work out of my home, to try to help people that are working on the front lines and actually feeling like we're actually making some progress in helping out, so at least through this first wave and hopefully, things will be better in the second wave and third wave, until we have a vaccine.

Jill:

Yeah. Dealing with a crisis like we're dealing with now isn't something new to your career, you've responded to other crises in your career as well, correct?

Mark:

Yeah. I never planned this at all, but my initial disaster response was in 1989 to the Exxon Valdez oil spill and the health and safety issues around workers in that cleanup, that massive cleanup over 10,000 workers in Alaska. That was my first foray and at the time I thought maybe my last disaster, because they're really hard and you're consumed throughout the disaster. It was a good six or eight months during the Exxon Valdez oil spill. That was everything that I did. Then it turns out years later, I was working with the Service Employees International Union in DC and that union has lots of health care members and then H1N1 hit and then suddenly, we were in what we thought was a pandemic then, at least an epidemic, for a good six months and that was pretty all consuming.

Then five years later, the Ebola crisis hit. Although we didn't see a lot of cases in the US, there was a huge amount of work to prepare and try to figure out how to deal with that from the healthcare industry. I thought that was probably the most intensive work I thought I would ever do because the Ebola work was seven days a week, probably 18 hours a day for six or eight weeks. It was pretty exhausting. But then now we're in the pandemic and this is a hundred times worse and it affects everybody and everything. Yeah, I'm looking forward to not having disasters in the future to work on.

Jill:

No kidding. I have talked to more health and safety professionals who have said that they've never worked harder in their careers and it's so interesting to think about that. You framed up in talking that you've been working from your home this whole time and so have many of us though many more have not. But we're working, myself included, harder than we have in our careers from whatever station we're doing that work from. We're working really hard.

Mark:

Yeah. Thanks to all of you that are working full time on this. This work is hard because it's... I mean, there's an end point, but it's really uncertain. We're looking at a year or more down the road probably before this really ends. The information is constantly changing. I mean, we went through the initial phase and then we went through the lockdown and now not everybody locked down, lots of people kept working and now we're back with reopening. There's lots of... there's a fire hose of information, reports and scientific studies that come out and guidance that comes out.

Although a lot of the basic CDC guidance hasn't changed dramatically, the CDC still says health care workers need respiratory protection, there's all sorts of caveats that if there's a shortage and if you can't get N95s, then all these other things that we never really seriously thought would take place are taking place, like using surgical mask instead of respirators and trying to act like that's okay or the decontamination of N95 50 cent respirators meant for single time use [crosstalk] and the idea that people are going to wear these full shift or multiple shifts and then we're going to [inaudible] them multiple times and give them back to people. I mean, these are things we'd never-

Jill:

Never, right.

Mark:

... expected to have to see, and I hope we get past it and never have to see it again. Yeah.

Jill:

Exactly. Mark, when you and I were talking prior to recording, you had mentioned that you really wanted to find a way to focus on something positive in this pandemic by way of your work and your contribution and you shared a couple of those things with me and you started talking about it right now with regard to respirators. Yeah. Can you talk more about what you've discovered and what you've been working on with, in that regard?

Mark:

Yeah. There's been a couple of key areas that I focused on and I realized early on that it was so overwhelming with what was happening and I was working primarily with health care organizations. It was so overwhelming. It was just too much. I realized I needed to focus in on a smaller number of areas where I could focus and maybe have an impact. It turned out, one of the early things that I had openings and I've continued to work on is, trying to encourage health care organizations to switch from N95 respirators, which are both in short supply and have their own, other sets of problems, but to switch to elastomeric reusable half face respirators with P100 cartridges. I was part of, I've been advocating that on and off for probably the last decade since H1N1-

Jill:

Interesting.

Mark:

... and without much success. When it's not a crisis, people aren't thinking about needing to switch types of respirators. But certainly now it's a more important issue and we're looking at this for a year or more, so what can we do to help protect healthcare workers? I presented in 2018 for the Service Employees International Union, who I was the Health and Safety Director at the time, and I presented at National Academy of Science meeting that was assessing the possibility of elastomeric respirators for use in healthcare, either in normal use or in surge uses like during a pandemic.

There was a report that came out and the panel did a really excellent report that came out just in early 2019 and it's now getting a lot of attention because we're in the middle of this pandemic, but the idea of using a respirator that... those of us in industrial hygiene, that's been a standard respirator used in many work sites, both environmental work, construction, industrial work for decades. But in healthcare, it's only been used by a small number of healthcare systems and mostly, either healthcare systems weren't aware of it, or they dismissed it as not something they needed to think about and [crosstalk 00:09:31]-

Jill:

Mark before you-

Mark:

... one thing that started to change... Yeah, sorry.

Jill:

Yeah. For anyone who... especially if anyone in healthcare is listening right now, and they're not familiar with what an elastomeric respirator is, can you draw a picture for people in their minds of what you're talking about in case they're not familiar?

Mark:

Yeah. Oh, sure. These are a reusable type of respirator. They're a face piece that covers the nose and the mouth and under the chin. Fits about half of your face, lower part of your face and it's a rubberized or polymer material. It has filters or cartridges that are replaceable. Then it has a harness so that it holds it tightly on your face and tightly against your skin so that you can... so it protects you. These costs between 20 and $40 depending on where you buy them and how many buy. The filters are a couple dollars a piece, and you can get filters that are equal to or better than the N95 filter that is commonly used in healthcare.

These can be cleaned and disinfected readily and then reused. The healthcare environment is pretty... is not a really heavy-duty environment for how these are made. These are often made for industrial and construction use. But in a healthcare environment, these will probably last a year, maybe more. The filters would last at least a few months, and maybe even more in a healthcare environment that's not dirty and dusty. You're only trying to capture the droplets that contain the virus particles out of the air.

These are a type of respirator that if health care institutions would use them, they don't have to worry about stockpiles of N95 and supplies and then not getting supplies, reusing the N95s over and over again, trying to decontaminate these again. They don't need to worry about switching from one brand to another, and then you have to refit test everybody because everybody would have one respirator and they could use that for an entire pandemic. I've been really pushing that this would be a really reasonable solution for the healthcare industry for this pandemic and beyond, but certainly during this pandemic, to get ready for the second wave and maybe third wave and help us protect healthcare workers and stop the exposures that we're seeing. I mean-

Jill:

Right. Are they more comfortable to wear as well, Mark, compared to let's say N95? We've all been looking at pictures of people whose faces have been abraded from trying to get the N95 to fit and fit tightly on their faces and they're working and sweating in them throughout their work.

Mark:

Yeah. Well, I generally try not to use the word comfortable with a respiratory.

Jill:

Okay, makes sense.

Mark:

Because anything you wear on your face for half an hour or more, and the longer you wear it the more uncomfortable it is. But, I don't think they are any more difficult to wear than the N95. I think there's real advantages to them. I think the harnesses and the way that they fit on the face is better. I think that it actually seals over a broader surface so there's less pressure, I think, on the skin. They fit better and if you're wearing these half mask elastomeric respirators, you can do a user seal check really readily on most of them and so you know when you put it on as a worker, that this is seated on your face right and this is protecting you.

Mark:

That's much harder to do on most of the N95 from my experience. The P100 filters are what we used to call HEPA filters. They're actually better filters than the N95, which is, the N95 is 95% filtration efficiency and the P100 is 99.97%. It's a better filter. Even though they're given the same protection factor rating, which is a measure of how well they sit on the face, I think most hygienists would agree that the half mask elastomeric respirator seals on the face better than the N95. I mean, I feel much more comfortable with N95 on to protect me against airborne hazards than I would an N95.

Jill:

Oh, you mean in elastomeric you are more comfortable?

Mark:

Yeah, elastomeric. I mean, it protects me better, I think and if you do the qualitative fit test or the quantitative fit testing, you can see that the protection factor, the actual protection of that respirator is generally way higher than what you would see with... when you do the quantitative fit testing on N95. The fact that they're reusable and that one per worker would last the entire pandemic, the whole issue of supply problems and shortage, which has been a huge problem and I know a lot of healthcare industries I talk to, they have people that are doing nothing but on the phone all day long, trying to find supply. If we had these, then that issue is not... and those several hospitals that have been using elastomerics, they're not facing supply issues like everybody else. They're able to focus on other issues of worker protection and getting the healthcare work done for the care they provide.

Jill:

Are the elastomerics readily available?

Mark:

Well, one of the problems early on... normally, they're readily available, but what happens is, many of the manufacturers make their elastomerics in Asia. The same issue we had with N95 and other respirators that are... many of which are made in Asia, the supplies shut down but it wasn't shut down as I can see it because everybody wanted them, they were shut down because of the pandemic. Those factories have now opened up and what I've been hearing even just this week is that, there seem to be ready supplies of elastomerics available, maybe not all the manufacturers and all the brands and all those styles, but if you want an elastomeric, what I'm hearing now is you can get elastomerics and even buy hundreds at a time, are now available.

Jill:

Fabulous. Yeah. Mark, what has your experience been in terms of talking with the healthcare industry and other industries? Have you been able to move the needle in your work and share news of this kind of respirator as a better perhaps, and as an alternative?

Mark:

Yeah. Well, it's been really mixed at this point. I've been... I mean, there were a couple of systems that have been using elastomerics actually for a long time. The University of Maryland Medical System, they started using elastomerics after H1N1, when they started seeing possible supply problems within N95 and they had a CIH Jim Chang, who had a lot of experience in other industries and he convinced them apparently to try elastomerics. They've been using elastomerics and N95s, but now they're using elastomerics and that helps them with their supply issues.

Jill:

Yeah, I've heard him speak. He was fabulous.

Mark:

Yeas. He and... there's a Dr. Stella Hines who's a physician and they've both been really strong advocates for the use of elastomerics and disinfecting and other use issues and they've been very generous with willing to go public and talk about why they're doing this and encouraging others in healthcare to do it. The other place that has done it actually, a facility that never used N95s, that started back in the late 1990s, when hospitals were switching to and that were using N95s for tuberculosis, they went right to elastomerics and they were the Texas Center for Infectious Disease. They're in San Antonio. They're a really interesting facility. They're a state-run infectious disease center. They mostly see TB patients, and this has been their history.

They have this campus in San Antonio. They have a lot of full-time patients who are there getting their TB treatments, but they also do other infectious diseases and they've been seeing COVID-19 patients. They started off... I was lucky enough to go down and visit. They were also incredibly generous about talking about their experience and I was able to visit their campus and meet them and tour what they were doing. They said that they never started with N95s and their issue was cost. They said, "When we started looking at how often, because we were... all of our staff are in daily contact with our TB patients," so they would be using lots of N95 and they said, "The cost seemed so large that we found elastomerics," and that it was mostly a cost issue. But they said, "Once we started to use them, we found that they were so much better to use, and the worker protection was better, that we've never looked back."

Jill:

Yeah. Interesting.

Mark:

They've encouraged other facilities to switch and without a lot of success until recently now with the pandemic. But those two institutions have been incredibly generous with both on the National Academy of Science panel review of elastomerics and sense, and especially during the pandemic, generous about sharing their experience and giving advice on what they think other people might do. There's been a number of healthcare systems that are with the shortages, have started to now talk to them and have started to look at using elastomerics, either on a pilot basis, and I worked with one hospital in Kentucky and they were happy to try out and to pilot elastomeric use among their nursing and physician staff that were going to be doing intubations. That's a high risk procedure and you're close to the patient. There's lots of chance for the patient to cough and so lots of potential exposure.

They weren't facing N95 shortages at the time, but they said this looks like a better idea. They were able to... I actually helped them get a small supply of respirators by talking to an environmental contractor that worked with the Asbestos Workers' Union that I knew people at and they were willing to donate a bunch of half mass to the hospital to help out. It was funny because the contractor who was [inaudible 00:20:47], the owner of the contractor, when I told him what I wanted, he said, "Well, we've already donated N95s to the hospitals." He said, "We never had a mass for elastomerics." I said, "Well, here's the little short history about that." He goes, "Well, this makes a lot more sense." He says, "We don't use N95 as much in our work. We use elastomerics as our bottom-line respirator."

Jill:

Yeah. Interesting.

Mark:

It was really wonderful to connect those people together. The last I've heard, they were doing fine. I hadn't heard that they have expanded to a larger group, but since then, the other hospital that I've done a little bit of work with is.... that I've helped with is the Allegheny Health Network around Pittsburgh and they've actually switched. They're switching over to elastomerics half mask in the last month or six weeks because of the shortage issues. I believe MSA has their headquarters there, and MSA has been working with them to help them do the transfer.

Jill:

With supply.

Mark:

Yeah.

Jill:

Sure.

Mark:

There's an article coming out that some of their medical folks have just written about the experience of transferring over to elastomerics. I haven't seen the published article yet, but it sounds like they have some really positive things to say about... Again, being willing to share their experience of how they as a healthcare institution looked at this and how they've adapted this. Some of the issues are, how do you do proper cleaning and disinfecting both between patients and at the end of the shift?

Jill:

Yeah, that's what I was just going to ask. What is the utility of that? What are people discovering works?

Mark:

Well, I mean, the use of these half-masks, they can be easily cleaned at the end of the shift and they can be dismantled. They key is to take out and to remove the cartridge, the filter, the P100 filter because if that filter gets wet, then that filter is no good anymore. You don't need to replace that filter all the time. The filters, What you need are the filters that have a hard-plastic case. Some filters have a covering that are designed to go over the filter. If you have one of those, you can clean the case or the filter itself. You don't need to get the filter wet, and you can clean that with disinfecting wipes that are commonly used in healthcare. It's kind of like bleach wipes that all the rest of us use. Then you can just take the rest of the face piece and you can wash it in soap and water, just standard soap and water, and then there's a bleach solution or other solutions to disinfect it in.

It's been shown in a number of studies, including the work at the University of Maryland, that these can be readily both cleaned and disinfected, so that you're not spreading any infection by using it. Between patients what they have is a multi-step process of using disinfecting wipes to wipe off the respirator so that a healthcare worker wearing this between patients can do a quick and dirty disinfecting, but it seems to be effective. It stops this, it doesn't allow for spread of COVID. It's not a hard thing that you can train workers to do and that workers can easily do. One of the big questions that comes up is, how do you handle the end of shift cleaning and disinfecting and inspection? The Texas Center for Infectious Disease, they make that an individual responsibility and they provide the supplies.

Jill:

I was just going to ask.

Mark:

Now, they're a smaller facility with probably 150 staff, I recall, and so they make that part of... what they present that the respirator is, and it's what I've seen in my environmental construction work is, they treat it as a tool that you, as a worker get as part of your job, and then you're trained to take care of it, you're given supplies and the time to do it. Then, because that's your respirator and it protects you, most of the time people do a really topnotch job of taking care of it because you're the one who suffers if you don't. But then they have, at the Texas Center they have in house staff in their respiratory division that does pulmonary function and other stuff that they've become the respirator experts and they're readily available.

Everybody knows who they are, and if you have any questions or issues, you go talk to them and then they help you. If you need a new respirator, they'll get that for you. They do the fit testing, they do the medical evaluations and all that. That's their model that seems to work really well for them. The University of Maryland Medical System, they have workers clean the respirators in between patients, but at the end of the shift then they collect these to a central point where they're cleaned and disinfected and inspected and put back together the next day.

Jill:

Sure. Probably similar to any other medical instruments that need to be cleaned.

Mark:

Right. Those are kind of the two basic ways when I talked of facilities that's usually a big question is, how do we do that? That brings up issues of how does your work flow, how much storage do you have? One of the downsides-

Jill:

Staffing to clean.

Mark:

Yeah. One of the issues that I think resonates with healthcare workers when I talk to them about elastomerics is, they like the idea that they could get their own respirator and that they would take care of it themselves and they're the only one who puts it on their face. If you use the centralized method, it would be better if you had a way to ensure that those workers who turned a mask in got the same one back, but that doesn't... if you've done a proper job of disinfecting cleaning, you don't need to do that. But what I found is, workers often are much more favorable if they know it's their mask that they're putting in and they're not sharing masks between people.

Jill:

Yeah. It increases the comfort. Yeah, and so if people aren't familiar with the fit testing that's required for those, can you walk through just a little bit about that, Mark, in terms of, is this something an entity can do on their own if they have never done that before?

Mark:

Yeah. The fit testing for an elastomerics can be done exactly the same way as a fit testing for an N95. OSHA has specific protocols that are required to be followed and that's in their respirator standard. There are qualitative methods where you test someone's fit to the respirator using a test agent that they can smell and taste while they do a series of exercises and so you can do that. It's the same protocol, whether you're wearing an elastomerics or an N95 and so you can do that. Then there's also quantitative methods using a machine and a computer that actually measures the fit and the seal of the respirator on their face. PortaCount is the primary manufacturer that makes that. There's a negative pressure unit that's also available.

You can use either method, but you can use either method on an N95 but my experience is the elastomerics are easier to fit tests because they tend to fit people better. There are hospitals that have actually had problems with different N95 styles where they can't get a lot of their staff to fit because a lot of the staff are women and their faces are smaller and the respirators are trying to fit and the N95 are designed for a male industrial workforce and so they just don't tend to fit as well. The elastomerics tend to have a much easier time fitting to the... you might do... most people will fit on the first try with the first selection and if not, usually the second try, most people will... you'll be able to find a smaller or larger size.

Jill:

Yeah, and they generally come in how many sizes, Mark?

Mark:

The elastomerics usually come in two or three sizes per each model. There's usually a small, medium, large, or a small-medium, and a medium-small, it depends on the manufacturer. The two major objections in healthcare that we saw at the National Academy of Science review was that, one was how they look. That they just looked weird to have these bigger face pieces on people's face and they're usually in black and they look more imposing. That was one objection, that it would put off patients and that's not an issue anymore, I don't think, because we're in a pandemic and I don't think there's any question about whatever people have on their face. No one's going to raise a ruckus about that.

The other issue was, could you disinfect these so that you don't spread infection to a facility? I think we've been able to see with the work from the Texas Center for Infectious Disease and the University of Maryland, and some of the... and NIOSH has done some work on this, that these things can be cleaned and disinfected and used in healthcare without becoming a source of infection and especially when we're looking at the reuse of N95s or the extended use of N95 or the deacon and reuse of N95. I think this is a much better choice to protect healthcare workers.

Jill:

Yeah. It sounds like the thing I'd want. Are you seeing it being used in other industries as well to protect from the virus? I know you had mentioned it's very standard kind of respirator to be used in industrial settings, but outside of healthcare right now to protect from the virus. Who else are you seeing using them?

Mark:

Well, as places are opening back up, I think we're seeing the use of, certainly in construction, I think. It's one that they can use, in building trades workers and other people that do building maintenance, who probably historically have used these respirators for led protection and asbestos work, they can... I don't think they realize early on that they could just use the same respirator. It needs to be mentioned that you don't need to go find N95, that you can use these, and they're actually better. I suspect there's going to be other... I haven't done a lot of work in industrial sites yet during the pandemic, but I suspect lots of industrial sites could get and use these respirators because it would fit with other protections they would need to provide anyway.

Because we can't forget about all the other hazards that people face on their normal [crosstalk 00:31:39]. Yeah. I mean, in healthcare, we have to keep remembering that it's not just... COVID-19 is the focus, but we still have bloodborne pathogen issues, and needle stick issues and we have say patient handling problems and lifting, and back injuries and we have workplace violence, which is showing up in some places. There's all these other issues that we have to deal with in a normal work are that much worse now, because everybody's focused in on the COVID-19. People are exhausted and tired. Work has changed. There's an unsettle... there's lots of people that are unsettled in what they're doing. I think all these health and safety issues during disasters get worse, in addition to-

Jill:

Yeah. Amplified for sure.

Mark:

Yeah.

Jill:

Yeah. Mark, I know that you've also been doing some work trying to raise awareness on Infectious Disease Standard and some work that California's been underway with for quite some time. Do you want to talk about that?

Mark:

Yeah. Thanks. The other thing, the other kind of work I've been doing that's been really... feels like I'm doing something positive is, work with health care organizations in California. In California, many people are not aware of this, but California has a state OSHA plan. They do their own enforcement, but they also can set their own standards. Federal OSHA doesn't currently have an infectious disease standard for respiratory disease, they have the Bloodborne Pathogen Standard. But in California after the SARS, the original SARS outbreak in Toronto and Asia in 2003, there was an interest from the healthcare employers and there were also concerned about TB. There was an interest from healthcare employers on doing something about fit testing, and use of respirators because at that point, it was new to many of those healthcare sectors.

They came to Cal/OSHA and they asked, was there some way they could figure out a way to get some relief from fit testing requirements for respirators. The Cal/OSHA staff to their great credit, they said, "Well," they didn't just say no. They said maybe, but we needed in the context of a comprehensive infectious disease standard for infectious disease. What they then did is, they pulled together stakeholders and they have a process in California with a standards board that's really good, and so they pulled together with the Cal/OSHA staff and they pulled together a meeting of healthcare and other employers that might be effected, labor organizations, of which I was working for the Service Employees International Union and community groups and public health folks and they brought people together over several years in lots of meetings to talk about what might the standard look like.

They ultimately came out with a standard in May of 2009. Now, May of 2009 was the... May 21st was the date, it was my birthday and I remembered that forever. I flew to San Diego where the standards board meeting was, and they were going to have their final vote with the board of the... it's a publicly appointed board by the governor with representatives across the employers, employees, public sector, public health. Their board had to vote to adopt or not adopt the standard. We had heard lots of good... everybody was feeling pretty good about the standard and there'd been a lot of good compromise like you need to get a standard pass.

Essentially what the standard did, it was a little more this, but essentially they took a lot of the CDC guidance from 2007, which was the latest update on their infection control procedures for healthcare. They put those procedures, they put those CDC guidance, which are voluntary into the occupational health framework of a standard, written in a typical way we see standards, like the Bloodborne Pathogen Standard. There's an exposure control plan and there's a section on PPE and there's a section on-

Jill:

Post exposure, follow-up.

Mark:

... post exposure, follow-up and training education and record keeping, typical standard that we in occupational health see. But it was going to become mandatory. It would be the minimum requirements for all health care institutions in California and it also covered nursing homes, public safety officials, police and fire department, paramedics, EMTs. It covered some high-risk populations like prisons and drug treatment centers and TB clinics and public health people that do outreach and testing, which has been really helpful for the pandemic because of all the testing that's going on.

At that final standards board meeting, everybody... I was never at an OSHA hearing like this, everybody from our side on the unions to public health, to the employers, all praised the state, all praised the staff. The staff got a standing ovation and it was passed unanimously. What the employers all said was, we can do this because we already comply with CDC guidance and better and so there's not a problem. This is fine. Cal/OSHA got an occupational health standard that deals with droplet and airborne spread diseases that became in effect during H1N1. It was in effect during Ebola. It covered Ebola. It was in effect during various whooping cough and measles outbreaks they've had and other infectious disease outbreaks and tuberculosis.

It's been around over a decade and it's had an impact on... it's not perfect, like no standard is and employer compliance hasn't been perfect, but it's a good model and it actually is the model for the draft Federal OSHA Infectious Disease Standard that's currently sitting out there waiting, we're hoping that it'll go into effect at some point.

Jill:

How long have you been waiting on the Federal end?

Mark:

Well, Federal OSHA started working on their Infectious Disease Standard about a year or two after Cal/OSHA had finished their ATD Standard.

Jill:

Okay, so eight of nine years. Okay.

Mark:

Yeah, it's gone through early regulatory process, it's gone through the small business SBREFA process. From what I've heard, it's not that far from being finished if the agency is simply told, we need a standard and it could be-

Jill:

Done.

Mark:

... out quickly and it would be out. The way it's been talked about is it would be out as a temporary emergency standard quickly within a timeframe for making it permanent but the temporary emergency standard would get us through the pandemic, and then there'd be more time to think about, "Okay, what worked? What didn't work? How do we revise it? How do we make it work better?" The hope would be, it could be as successful as the Bloodborne Pathogen Standard, which in its 30 years in existence has had an amazing success at reducing a bloodborne pathogens, especially Hepatitis B in healthcare workers from... we used to have 300 or more healthcare workers a year die from Hepatitis B and now almost nobody dies from Hepatitis B in healthcare.

Mark:

Needle sticks have been reduced and lots of other positive. I don't think anybody or few people in healthcare would say, "Let's get rid of the Bloodborne Pathogen Standard," but they didn't want it when it... employers don't like standards, they don't like requirements and so there was a lot of opposition to it, but now it's become... it really transformed the industry. Dr. Michaels, who was the head of OSHA under the last administration used to point to the Bloodborne Pathogen Standard as the best example of OSHA driving a sector into better health and safety and really driving the industry in a better direction. I think a National Infectious Disease Standard could do the same thing with all the issues we're running into right now.

Jill:

Yeah. Mark, how is the California standard working right now? I mean, is it being utilized? Is it being enforced during this pandemic? What's happening?

Mark:

Well, that's one of the frustrations I've had is, the standard is on the books. It covers the COVID-19 as an airborne and droplet spread disease and so there's a comprehensive standard. Employers are required to have a... covered employers, hospitals, nursing homes, others are required to have a comprehensive exposure control plan that is like the... the version of the plan like they have for bloodborne pathogens. They write their own site-specific plan following the requirements of the standard, and then they have to follow it and then the Cal/OSHA can then enforce that standard that they've written for themselves. The downside is that since the... early in the pandemic, the governor of California put all the regulatory agencies in California on voluntary compliance mode, which is not uncommon during disasters, OSHA, Federal OSHA has done it, State OSHA programs have done it.

But because of that, Cal/OSHA is not focused on issuing citations or issue on trying to help employers meet the ATD Standard and other standards for the pandemic. Unfortunately, many, many employers that I've talked with are ignoring the standard and they're... actually, what they say is, "We're following CDC guidance or the World Health Organization guidance," and I always retort and say, Well, that's fine as long as that guidance meets or exceeds the ATD Standard." In most cases, it doesn't. The ATD Standard has better protections for workers. But there are some employers who are trying to do the right thing, but the vast majority of them are probably not as organizations. Part of that's driven by the kind of overwhelming nature of the pandemic. Part of it is driven by the lack of N95 respirators and other protective gear, the shortages that people run into or the blockages that people run into.

My hope is that... I've been pushing and working, we've been doing training with workers and unions about the standard and I think Cal/OSHA is now actually gearing up to do some more enforcement in the more egregious situations where workers, healthcare workers have actually died because the standard wasn't being followed. Hope I have is that when we get to the second wave, third wave or further into this long pandemic, that there'll be better compliance and employers will look at the standard, not as a burden, but as something that's really going to help them do better.

Jill:

Yeah. Just for people listening who aren't from California, or maybe haven't heard of California's ATD Standard, we'll include that in the show notes, along with a guide that you've told me about, Mark, that's easy to consume, a little bit different than reading a regulation as well.

Mark:

Yes.

Jill:

If people want to see what's out there, they can. A question for you, I guess if you want to comment, you had mentioned that Federal OSHA has the ability to put something together in an emergency situation and they could, in this regard, with what they've got in draft. If safety and health professionals listening to this want to advocate for that, where would they bring their voices?

Mark:

Well, I think the first place, bring it to your professional associations, because I think there's been some support among the health and safety professional associations that there's a need for OSHA to be doing more than they're doing and having an infectious disease standard, which set at least minimum guidance for employers like health care, food processing, others who never shut down, but with the reopening and all this massive programs that have tried to figure out how to reopen in the time of COVID, to give some minimum guidance to employers would be really helpful and instead of everyone just making everything up. The thing I keep going back to is, the CDC has been putting more guidance up on their website and some other federal agencies and some state health departments but the problem is those are all voluntary. They're all guidance's. No employer has to follow those unless they want to.

Jill:

It's like everything prior to 1970.

Mark:

Exactly. I mean, I've had times, and you probably felt the same way in the past few months where I think to myself, "Oh, this is what it was like before OSHA, when employers didn't have minimum requirements," and it was hard for us to push back, whether you're a consultant or working on staff or working with a union. I mean, you're really facing, trying to get the organization to do the right thing from a health and safety point of view. As much as we might not like, or not think the OSHA Standards are good enough in some areas, they were always a minimum floor that we could point to, to at least push our profession and push the health and safety protections for workers.

That's really needed now with... I mean, I think back to the fact that we have in this country some... we don't even have a good number for it, but it's been estimated between 500 and a thousand healthcare workers have died from the COVID-19. I mean, what type of occupational disease where that many workers are affected in such short period of time, and there's essentially nothing or little done from Federal OSHA. I mean, it's really-

Jill:

As a dramatic reaction. Yeah, absolutely.

Mark:

It's really stunning. It's not all employers, but to see many employers, either ignore guidance that they know is out there for whatever reason they're deciding to do that or to have what... I've been working more with some small employers or small businesses where they're really struggling because they don't have the expertise and experience and so they really need those minimum guidance's to help them get started. They don't really even know where to get started.

Jill:

Yeah and if there's a framework, people should be able to have it and have access to it.

Mark:

Yeah. Then the other part is, with the small businesses, they look at a lot of the checklists from CDC and I try to remind them that that's the minimum requirement, that you could probably do better and do more and be more protective or be ready in case something changes in the future and build in the creativity of your own experience at the work site that you know so well, as opposed to generic guidance from CDC or someone else and get them to think more creatively about that because I've seen that in my career be really where people move forward on safety and health. I think a minimum standard would be a way to help get people further along, yeah.

Jill:

Right. Right. Yeah, and Mark, you've also been doing some education rather around reopening with some smaller entities as well and trying to do some education with them. Can you talk about some of the things that you've been sharing?

Mark:

Yeah. I've been just through folks I've worked with over the years, I'm getting pulled in like most of us into questions about reopening and how to use the hierarchy of controls in our profession to think about that. I actually had this really interesting work that we're just finishing, is actually my wife and I, my wife is an acupuncturist and she's a sole practitioner, she runs her own practice. I'm in Columbia, Maryland. She works out of our home now. She used to work out of a clinic. Never expected our two professions would intersect, but it turns out with the reopening, a lot of... she closed her practice down early on and as did most of her colleagues and now with the reopening across the country, a lot of her colleagues were starting to think about how to reopen.

They were talking about their profession being a low risk profession and they were talking about using KN95 respirators as if they were real respirators. We have all that controversy. I ended up offering to say, I'd offer to volunteer to do some training for a few people if they wanted to think about how we in occupational health do this. These are people that have never done occupational health work. They've not had to deal with these issues. They are small-

Jill:

Might not know what OSHA is.

Mark:

Yeah. They're small businesses. They're typically not covered by OSHA or they're less than 10 employees, but they were interested because it's protecting their health and their patients. Their patients are important to them. My wife put out on the listserv, we said, "Well, we'd be willing to do a class," thinking maybe 10 or 15 people would say yes, and we'd do something informal. Well, two days later, over a hundred people had signed up. We ended up doing a series of five training courses, two and a half hours each over Zoom, which has its own challenges. I got support from one of the NIHS Worker Training Program grantees at UCLA, the Labor Occupational Health Program was very generous and they said, "We can support this work."

We're trying to do reopening and thinking about how to reopen. This'll be a useful kind of focused work. If you think about it, acupuncturists are sort of an allied health profession and there are probably, 15 or 20 million people who have small businesses or sole practitioners who do this kind of work. I mean, everybody from massage therapists to physical therapists and all sorts of other professions where they see people in a close setting, they have small offices, so is-

Jill:

I do it myself, Mark, in my non-safety world as a reiki practitioner.

Mark:

Yeah. Yeah, so-

Jill:

Yeah, so I'm listening.

Mark:

The goal was not to tell people whether they should open or not, or how to do it. The goal was to explain from an occupational health point of view, given the experience of our profession. We've helped industries from construction industries learning to deal with asbestos and other chemical exposure and industrial industries had to deal with silica dust and these things that they hadn't dealt with in the past. We had that experience in a focused way. We framed the class around the hierarchy of controls and how to think about layers of protection that you could figure out for your work site, with engineering controls and then work practices, and then PPE last and how you could...

So if you can't get N95s because they were in short supply, what could you do to reduce exposure to the aerosol spread in your... by having fewer patients or using more rooms and fewer patients per room, how could you set up temporary ventilation between patients that might help clear out the space? All sorts of things that people hadn't been thinking about. We ended up doing these five classes. They were really wonderful. I feel bad at times because the practitioners didn't want to hear about aerosol spread because that was something they hadn't heard before and that made this reopening harder. They wanted to hear that KN95 respirators from China were equal to N95.

Jill:

Were going to work.

Mark:

Many of them had purchased those respirators from suppliers under the recommendation that they were respirators, but of course, we know they're not.

Jill:

They are not.

Mark:

I had to give people bad news, but what I really was encouraging is that people needed to be thinking and creative and that this was something that could be done. It's not easy. It took work and you have to practice and you have to be ready to revise and practice again but that you could do it, but you needed the framework to think about it. I think the industrial hygiene hierarchy of control framework was perfect and it really resonated. I've gotten a lot of good feedback from those practitioners who now understand what the hierarchy of controls is, who didn't know what that was six weeks ago.

Jill:

That's so awesome.

Mark:

I think it's an interesting model, not just for the work that my wife does and I'm an acupuncture patient, so I would think about it as well. I'm the patient. I want you to be protected because I don't want you to make me sick if I'm going to come see you.

Jill:

Right, exactly.

Mark:

You at the reiki and your patients, the same thing. But I was really thinking that there really are a lot of people who are small businesses who are trying to think through these issues and so I was really trying to learn for myself, what lessons can I learn from this work with acupuncturists that I could broaden out to help other small businesses? I'm now working with the LOSH Group at UCLA and others and we're thinking about how to broaden out these principles and do this as part of the work of our profession to help with the reopening and if people are going to go down that road. At some point people are going to have... everybody's probably going to reopen at some point before we have a vaccine.

Jill:

Yeah. Well, what a wonderful contribution that is. I know you and I have talked about the possibility of perhaps maybe you'd be able to capture some of those best practices you're talking about as a guest blog, that we'd be happy to socialize to small businesses like you're talking about right now. I think that'd be a great contribution and help to people.

Mark:

Thank you, Jill. I'd be glad to do that and thank you for the offer.

Jill:

Yeah. You're welcome. Mark, this has been such a pleasure and thank you for bringing, as you said, something positive to focus on. The work that you're doing is definitely having an impact. I'm sure people listening to this episode will be... these are things they hadn't thought of before and especially any audience, particularly in healthcare who hasn't heard of elastomerics respirators before, or didn't know that California has had a standard for 10 years, that people could be using as a guide right now. How powerful is that? I'll include that information in the show notes as well. Really appreciate it and thank you for the tireless work. After 40 years and you think maybe this is going to be the coast and all of a sudden, it picks up speed like never before.

Mark:

Well, thank you, Jill. It's always wonderful to talk to you and talk about these issues. Yeah, I'll be happy when the pandemic's over and we're past this and we can all go back to "normal" and I can go back to my historical film channel and just work on history of our profession. After my golden years-

Jill:

Absolutely. There's going to be a lot. Yeah. There'll be a lot more history to talk about after this as well.

Mark:

Yeah, and my great admiration for everybody, all of your listeners who are working in this field, either in healthcare or in safety and health that are working so hard on doing this, so stay safe and keep up the good work everybody. It's so important these days.

Jill:

Thank you. Thank you. Thank you all for spending your time listening today and more importantly, thank you for your contribution, making sure your workers, including your temporary workers, make it home safe every day. If you'd like to join the conversation about this episode or any of our previous episodes, you can follow our page and join the Accidental Safety Pro community group on Facebook. If you're not subscribed yet and want to hear past or future episodes, you can subscribe in iTunes, the Apple Podcast App, or any other podcast player that you'd like.

You can also find all of our episodes at vividlearningsystems.com/podcast. We'd love it if you could leave a rating and review us on iTunes, it really helps connect the show with more and more safety and health professionals like Mark and I. If you'd like a suggestion for a guest, including if it's you, you can contact me and make that suggestion at [email protected]. Special thanks to Will Moss, our podcast producer. Until next time, thanks for listening.