The Board at Energy Outwest just wanted to touch base with all of you during these challenging times. We are currently working on our conference which is scheduled in August and hopefully the world will be back to normal at that time. We are keeping apprised of the situation, watching for updates from the CDC, and adapting and responding to change. Continue to check in with our website and our Facebook page for updates regarding the conference and other Energy Outwest activities. Your health and safety is our priority and decisions will be made accordingly. Please take care of yourselves, your clients and your families. We will be posting information and notices from DOE and other agencies regarding the evolving situation.
We have a collection of links to information related to COVID-19 relevant to performing weatherization. We will continue to add more links that seem to have value.
National Pesticide Information Center
Using Disinfectants to Control the COVID-19 Virus
List of states and their WAP Production Status
OSHA: Guidance on Preparing Workplaces for COVID-19
The Energy Conservatory (TEC) Is it Safe to do a Blower Door Test During the COVID-19 Pandemic?
North Dakota Commerce: Considerations for Fieldwork
Vermont Department for Children & Families Office of Economic Opportunity: PPE Chart
Wyoming Weatherization Assistance Program (WAP): Safety Saves Newsletter - COVID-19
Wyoming Weatherization Assistance Program (WAP): Emergency Preparedness, Disaster & Continuity of Operations Plan Guidance March 2020
Wyoming Weatherization Assistance Program (WAP): COVID-19 Pandemic/Infectious Disease Checklist
In response to a question about masks and addresses some of the issues with "extended use" and "reuse" of N95s.
Weatherization work is classified as Moderate Risk.
Reading the OSHA pyramid of worker risk the lever point for moderate risk seemed to be workers who had to be within 6 feet of members of the public. If I am reading this right curious why the training suggests that WAP workers in homes are always moderate risk. If there was a case where a worker could guarantee they would not be within 6 feet could they then be in the low risk category?
The OSHA Risk levels are based upon contact with coworkers and public…not the distances. Here’s the Low Risk Criteria:
Jobs that do not require contact with people known to be, or suspected of being, infected.
• Workers in this category have minimal occupational contact with the public and other coworkers.
I think this Low Risk Level is identified for people working at home. I would suggest you contact your OSHA compliance assistance organization to see how they are interpreting these risk categories.
Being 6 ft away lowers the opportunity for infection. However, the data available indicates the variability distance for droplet transmission factors are air flow directions, level of droplets produced by an infectious person (sneezing and coughing), humidity, etc. Viable virus is found in some studies up to 27 ft. The 6 ft recommendation is based upon SARS and MERS data. We do not yet have confirmation that the 6ft distance is sufficient for COVID-19.
At issue is the definition of ‘infected’. Since CDC/WHO haven’t figured out the exact mode of transmission, and asymptomatic people may be infectious, it’s hard to determined where anyone is known (ill or tested) or suspected of being infected. Minimal contact is being interpreted in NM OSHA as contact with less than 5 people (based upon our Governor’s orders). Minimal contact might go up to 10 people soon…but this is just a guess on my part at this point in time based upon how NM OSHA is following our Public Health Dept’s orders.
Regarding the section of the training that mentions that OSHA is waiving enforcement for organization that make reasonable efforts to provide substitute PPE. Do you know the specific references in the guidance for this?
Link: OSHA - COVID-19 Enforcement Guidance
Link: OSHA - Enforcement Guidance for Respiratory Protection and the N95 Shortage Due to the Coronavirus Disease 2019 (COVID-19) Pandemic
OSHA is not waiving enforcement…they are being ‘flexible’ in enforcement with regard to respiratory protection.
Here’s the paragraph:
OSHA will, on a case-by-case basis, exercise enforcement discretion when considering issuing citations under 29 CFR § 1910.134(d) and/or the equivalent respiratory protection provisions of other health standards in cases where:
The employer has made a good faith effort to obtain other alternative filtering facepiece respirators, reusable elastomeric respirators, or PAPRs appropriate to protect workers; (In other words…not just home-made face coverings)
The employer has monitored their supply of N95s and prioritized their use according to CDC guidance (Document efforts to get N95s)
Surgical masks and eye protection (e.g., face shields, goggles) were provided as an interim measure to protect against splashes and large droplets (note: surgical masks are not respirators and do not provide protection against aerosol-generating procedures); and
Other feasible measures, such as using partitions, restricting access, cohorting patients (healthcare), or using other engineering controls, work practices, or administrative controls that reduce the need for respiratory protection, were implemented to protect employees.
Where the above efforts are absent and respiratory protection use is required, or voluntary use is permitted, and an employer fails to comply with fit testing, maintenance, care, and training requirements, cite the applicable provision(s) of 29 CFR § 1910.134 and/or other applicable expanded health standards as serious violations.
Just to clarify, face coverings are for citizens/clients to protect them from workers. OSHA is requiring respiratory protection for workers. N95s or better, surgical masks and eye protection if N95s are not available. N95s should not have exhale valves if you are concerned about at risk clients. Exhale valves allow droplet release from workers. However, if you use an administrative control of keeping clients in another room (basically a ‘partition’ or ‘barrier’ and clean/disinfect thoroughly at completion of tasks, that should be protective. Document it, though.
And, we are not allowed to modify safety equipment (using duct tape on exhale valves) without written permission from the manufacturer. (I had a chuckle at that suggestion, my OSHA compliance officer really laughed. ) It’s too complicated to fully explain here. Cliff Note Version: the texture, weave, porosity of the mask is engineered to allow filtration of contaminates based upon pressure variability in the mask from inhalation and exhalation. Change those pressures and you need a different material to meet the established specifications. Put duct tape on an exhale valve and the material is not engineered to allow the CO2 to permeate from the breathing zone. After about 2 hours, you will have workers with horrible headaches.
N95s are designed for 8 hours of use. After that, the material is saturated with sweat and spit that further restricts air flow in the mask. In my experience, I need to walk outside and take off my mask about every 2 to 3 hours just to breath unrestricted air. OSHA requires medical evaluation to wear respirators because of the air restriction and the impact it has on lungs and heart. People with less than 80% lung capacity can be put into serious physical stress wearing an air purifying respirator for extended periods of time. People wearing N95s should be monitoring their pulse. Increased pulse rate could indicate serious respiratory and circulatory issues. Temperature and humidity can also be factors. Link: OSHA - Heat Hazard Assessment