Compliance Corner: Return to Work Safety Plan
The COVID-19 pandemic has brought unwelcome challenges overnight, leaving the healthcare industry floundering in a sea of change; it seems that every service line now must assess, pivot and adopt safety procedures aimed at reducing the risk of care. My goal for this compliance corner is to highlight the resources and standards required to develop an enhanced and ongoing safety plan for your sleep center.
The CDC and OSHA have published guidelines in an effort to reduce facility, patient and employee risk of community transmission of the virus. The AASM has reviewed federal and state policies and has provided updated mitigation strategies for sleep center clinical operations. The AAST has created a resource page to assist sleep technology professionals to better navigate the standards. I encourage you to visit these sites frequently for updates. The purpose of this article is to address employee safety plans.
As we operate our sleep labs during this pandemic state governors have mandated that we adopt a revised safety plan; whether your center continued to operate during the stay at home orders or is just now reopening. The plan must be written, provided to all employees and posted publicly. It is an expectation that all employees, including management, play their part in helping minimize the spread of COVID-19.
The safety plan requirements are found in state level executive orders and usually include these four basic elements:
- Institute a health screening process;
- Employ enhanced cleaning and disinfecting protocols for the workplace, including regularly cleaning high-touch surfaces;
- Enhance the ability of employees, customers, and clients to wash hands or take other personal hygiene measures such as use of hand sanitizer; and
- Comply with social distancing requirements established by the CDC, including maintaining six-foot social distancing for employees and members of the general public when possible.
The foundation of the safety plan is preventative measures and guidance that includes:
- Stay home when sick,
- Perform frequent handwashing,
- Avoid touching eyes, nose or mouth,
- Follow appropriate respiratory etiquette (covering the mouth and nose when you cough or sneeze),
- Avoid crowding or close physical contact (stagger break room use, reduce size of groups to (10) while accommodating 6ft distancing, configure workspaces appropriately),
- Avoid using other workers’ phone, desk, or office whenever possible,
- In lieu of a water cooler, use individual water bottles,
- Define whether employees and visitors are to use face coverings while at work,
- Limit access of family members and other non-patient visitors to those required for providing health care services,
- Consider having patients and visitors wait in their vehicles instead of in waiting areas, post phone numbers to call to inform you of their arrival,
- Monitor and secure PPE supplies.
Protective measures are critical for a successful safety plan. Education is an important part of that plan. All employees must familiarize themselves with the symptoms of COVID-19.
All employees entering any workplace will be subject to a health screening process. If an employee answers yes to any item on a symptom health screening questionnaire and/or has a fever of 100.4 F or higher the employee will be asked to return home and not report to work until at least 72 hours after recovery. Screening should be done at the point of access to the workplace. This may mean that employees who do not have a manager on site must self-report any symptoms and perform a temperature check prior to clocking in to work. Reporting logs should be maintained and kept private. State and County Public Health Orders outline when employees can come back to work. Typically, the employee with symptoms of COVID-19 may not return to the workplace until:
- At least 3 days (72 hours) have passed since symptoms have resolved (without the use of fever-reducing medications) AND
- At least 10 days have passed since symptoms first appeared.
- Note: The above criteria do not apply to anyone who, after showing symptoms, receives a negative COVID-19 test.
Employees are also screened to determine if they have been in close contact with a positive person or traveled via airplane, have been advised to self-quarantine or have tested positive for COVID-19. These employees will need to comply with required quarantine guidelines and to the same return to work guidance.
There is also an emphasis in finding alternatives to in person meetings; telephone or virtual meetings are preferred. Consider other ways to minimize person-to-person contact. Alternative HSAT service models may be used, such as mail delivery or curbside distribution and drop off of units.
The safety plan must include COVID-19 related cleaning measures and should reference the OSHA Guidance on Preparing Workplaces and the CDC Cleaning and Disinfecting Guidance. Based on what is currently known about the virus, and similar coronaviruses, this is spread from person to person most frequently with close contact. Transmission occurs via respiratory droplets, but the virus has been found to remain viable for hours to days on surfaces made from a variety of materials. Cleaning of visibly dirty surfaces, followed by disinfection, is a best practice measure for prevention of transmission of COVID-19 and other viral respiratory illnesses in community settings. Employees must be aware of the necessary precautions and the supplies needed and available to properly clean and disinfect surfaces and equipment. Provide personal protective equipment for staff, disinfectant wipes throughout the facility, hand sanitizer in offices, and appropriate cleaning supplies.
Ensure that a designated staff member is regularly monitoring for facility, state and local health department updates on COVID-19.
Make all staff aware of the need for:
- Frequent cleaning and disinfecting of shared work areas and common tools and equipment with appropriate disinfecting products.
- Frequent cleaning and disinfecting of high touch services, including doorknobs, handles, keyboards, telephones, tables, etc.
- Frequent cleaning of shared break/lunchroom/bathroom areas with appropriate disinfecting products.
- Enhanced personal hygiene measures.
All employees must wash their hands with soap and water regularly and thoroughly, including at the beginning of each shift, before and after patient care, and upon returning from any break. In addition, frequent use of hand sanitizer and no touch disposal receptacles is recommended.
In the event of identification of a confirmed or suspected COVID-19 diagnosis the CDC recommends:
- Closing off areas visited by the ill person.
- Opening outside doors and windows and the use of ventilating fans to increase air circulation in the area.
- Waiting 24 hours, or as long as practical, before beginning cleaning and disinfection of the area(s).
It is unknown how long the air inside a room occupied by someone with confirmed COVID-19 remains potentially infectious. Facilities will need to consider factors such as size of the room, the ventilation system design, and location of supply and exhaust vents when deciding how long to close off rooms or areas used by ill persons before beginning disinfection. Cleaning staff must clean and disinfect all areas such as offices, bathrooms, common areas, shared electronic equipment such as tablets, touchscreens, keyboards, remote controls, and equipment used by the ill person, focusing expressly on frequently touched surfaces.
Note that the items outlined are only suggestions. Be specific in your safety plan to outline what needs to be addressed at your center. Consider adding machine inlet and exhalation filters to PAP circuits and use of disposable patient sensors. Assure all staff have an appropriate understanding and competence with manufacturer cleaning recommendations.
This a good opportunity to perform a facility risk assessment and take a comprehensive look at all employee and patient care areas. All managers are responsible for ensuring that appropriate disinfecting and housekeeping practices occur on a regularly scheduled basis. The use of logs and assigned duties will be critical to manage this.
The safety plan should outline your social distancing requirements. All employees, customers and any visitors must follow the social distancing requirements established by the CDC including maintaining 6-foot social distancing when possible. In addition, include the expectation that employees and visitors wear a mask or face covering.
The safety plan encourages workplace flexibility. This may be a good time to consider shared or split workloads, especially when childcare may be of concern for employees. Assess the feasibility of work at home, which can help to eliminate overcrowded offices. This is also a good time to review sick leave policies and make adjustments to incorporate alternative documentation protocols for return to work, minimizing requirements for employees to visit healthcare providers prior to returning to work.
Re-train all employees on the proper use of any required PPE, the proper use of cleaning chemicals and disinfectants, and handwashing and infection control expectations. This should be done at the time the facility is re-opened to assure staff education is current, and documentation of training should be kept in employee file along with the employee’s acknowledgment of understanding of the revised safety plan.
There is a specific concern in the sleep center related to PAP titration studies, as this procedure does present a high risk of aerosol transmission. Staff must utilize appropriate PPE, such as N95 respirators, face shields, gowns and gloves. Employees will need an N95 FIT test to assure proper use and protection. The FIT test documentation should be kept in the employee chart.
OSHA Issues Training Resources for Respirators
On May 5, 2020, the U.S. Occupational Safety and Health Administration (OSHA) announced that it is releasing a new video and poster (available in English and Spanish) for employers and employees regarding how to properly wear and remove a respirator. Both resources offer seven steps, which, according to OSHA, “every worker should follow when putting on and taking off a respirator”.
These seven steps include:
- Wash hands with soap and water or alcohol-based hand rubs containing at least 60 percent alcohol before putting on and after removing the respirator;
- Inspect the respirator for damage;
- Cover mouth and nose with the respirator and pull strap over the head so that it rests at the back of the head. A second strap should rest at the back of the neck. Use the metal nose clips to mold the respirator to the shape of the nose;
- Adjust the respirator by placing both hands over it and inhaling and exhaling. Readjust the straps if air leaks from the respirator's edges;
- Avoid touching the respirator while wearing it;
- Remove the respirator by grabbing the strap(s) from behind. Do not touch the front; and
- If the respirator does not need to be reused because of supply shortages, discard it in a closed-bin waste receptacle.”
Employers that have determined respirators are necessary or appropriate for use in their workplaces may wish to incorporate these new OSHA materials into their training programs. In areas where N95 masks are in short supply, surgical masks placed over the N95 mask while in contact with a patient and discarded between patients may be useful to prolong the useful life of the N95 mask.
I am sending my gratitude and appreciation for all of the strength and unity our sleep community has shown during this international emergency. While the coronavirus pandemic has upended life for nearly everyone, healthcare workers, first responders and other essential workers have had to face more risks than most. I would like to join the AAST community in thanking all of those who are providing essential services during this difficult time. Be Safe and Sleep Well.
COVID-19 Resources Page
AAST has created a COVID-19 Resources web page to help sleep technology professionals better navigate through this period of great change.