**COMMENTS ON**

**OSHA Docket Number OSHA-2008-0005**

**Proposed Guidance on Workplace Stockpiling of\
Respirators and Facemasks for Pandemic Influenza**

17 June 2008

David L. Spelce, MS, CIH

Navy and Marine Corps Public Health Center

Industrial Hygiene, Acquisition Technical Support Division

This document provides excellent guidance on classifying occupations
according to the degrees of risk associated with health care procedures
and exposure to the general public. It also provides guidance on
estimating the percentage of employees who fall into each risk category
to determine total numbers of respirators needed for stockpiling.
However, we are concerned that it does not address what sizes of
respirators to stockpile. As mentioned on page 5, respirators used to
reduce employee exposure must be used in the context of a comprehensive
respiratory protection program, which includes fit testing. Therefore,
just as important as stockpiling an adequate number of respirators is
ensuring that there are sufficient numbers of different sizes of
respirators available to correctly fit all users. For example, we have a
hospital stockpiled with thousands of filtering facepiece respirators.
The selected respirator model is available in five sizes, but the
hospital purchased only the medium size. This resulted in merely 40 % of
the health care providers passing their fit test (with medium
respirator). Corrective measures are underway, but similar situations
can be avoided if the guide clearly addresses respirator size selection.

To assist in the process of ensuring that correct sizes of respirators
are stockpiled, recommend the guide emphasize prerequisite requirements
for wearing respiratory protection. That is, a respirator program must
be completed **prior** to facing a pandemic influenza. This can be
accomplished by ensuring that the OSHA *Pandemic Influenza Preparedness
and Response Guidance for Healthcare Workers and Healthcare Employees*,
Appendix C, is fully implemented. In fact, meeting the respirator
program requirements (especially fit testing) up front means that you
will confirm the respirator makes, models, and sizes prior to -- or at
least concurrent with - the stockpiling effort.

This document provides guidance on stockpile management. It would be
prudent to emphasize that as with all respirators, stockpiles of stored
respirators must be maintained in pristine condition.

More guidance is needed concerning replacement of elastomeric
respirators and PAPR filters. The guidance on page 7 states that two to
three filter sets should last for the duration of the pandemic. In
contrast, disposable respirators worn in the presence of infectious
individuals must be disposed of after use because they are considered to
be contaminated with infectious material. Replaceable filter media will
also be contaminated with infectious material if worn in the presence of
infectious individuals. Touching replaceable filters may (like touching
filtering facepieces) increase the potential for contamination through
contact transmission. Further, there are different types of replaceable
filters. Cartridge type filters would be easier to safely replace
because the filter media is essentially enclosed inside the cartridge.
In contrast, "pancake" type filters are not contained in a canister,
leaving practically the whole filter exposed. This makes touching the
exposed (i.e., infectious) filter media during replacement almost
unavoidable.