The Occupational Safety and Health Administration (OSHA) recently issued COVID-19 guidance for ensuring adequate ventilation in the work environment that can help to maintain a safe and healthy workplace that benefits both staff members and residents. The publication indicates that employers should work with HVAC (heating, ventilation, and air conditioning) professionals to determine if their facility’s ventilation system is functioning as it should.
The following tips are suggested to help reduce the risk of COVID-19 exposure:
- Encourage staff members to remain at home when they are ill.
- Confirm that HVAC systems are functioning properly particularly if their operation capacity has been reduced or shut down during the pandemic.
- Ensure that personal fans do not blow air from one worker to another.
- Use Minimum Efficiency Reporting Value (MERV) HVAC system filters that are rated 13 or higher.
Increase the HVAC system’s outdoor air intake. - Exhaust air should not be pulled back into the building from HVAC air intakes or through open windows.
- Use portable high-efficiency particulate air (HEPA) fan/filtration systems to increase clean air, especially in higher-risk areas.
- Wear appropriate personal protective equipment (PPE) when changing filters.
- Exhaust fans in restrooms should be functional, set to remain on, and operating at maximum capacity.
- Workers should be encouraged to report safety and health concerns.
The publication may be viewed at: https://www.osha.gov/Publications/OSHA4103.pdf.
Compliance Perspective
Issue
Failure to address a facility’s inadequate, poorly maintained, or ill-functioning HVAC system may contribute to the spread of COVID-19 among staff members and residents and result in the issuance of OSHA violations with potential fines and other sanctions. Additional citations could include failure to provide a safe environment and an Infection Prevention and Control Program that does not address the need for a properly functioning HVAC system. This may be considered provision of substandard quality of care, in violation of state and federal regulations.
Discussion Points
- Review policies and procedures to ensure integration with OSHA’s guidance for adequate ventilation and the facility’s HVAC system maintenance protocols. Also consider whether to consult an HVAC professional to evaluate the facility’s system.
- Train staff who are responsible for the HVAC system on the protocols for maintaining adequate ventilation and how to prevent the spread of COVID-19.
- Periodically audit to ensure that the HVAC system is functioning adequately, and that OSHA’s guidelines are being applied.
