ATD FAQs: First Responders
Primary Care Physicians & ClinicsClick here to download a summary sheet for primary care physicians and clinics from the Division of Occupational Safety and Health [DOSH].
ATD Standard TextClick here to download a copy of the approved ATD Standard text.
2. Are there any requirements of the Standard that will specifically affect the ambulance industry?
3. How does an employer know which ATDs are covered?
4. How can I reasonably control the exposure of ATD’s in an ambulance setting?
5. What kind of masks is required by the Standard?
6. As an employer, what are my requirements to protect my employees?
7. As an employer, what liabilities can I face?
1. I operate a small ambulance service. Do I fall under the Aerosol Transmissible Disease (ATD) Standard?
A. Yes. Any of the following apply:
- Medical outreach services;
- Paramedica and emergency medical services;
- Facilities, services, or operations that are designated to receive persons arriving from the scene of an uncontrolled release of hazardous substances involving biological agents; and
- Medical transport.
2. Are there any requirements of the Standard that will specifically affect the ambulance industry?
A. Yes, while there are some specific policies that will have to be
designed for the ambulance industries. Two important areas that will have to
be covered include:
- "Hand-off" or transfer procedures when picking up or dropping off a patient from another ATD Standard employer including hospitals and elder care facilities;
- Immunizations;
- Employee exposure and/or prophylaxis, and
- Policy required for "surge" planning.
3. How does an employer know
which ATDs are covered?
A. All ATDs covered by
the Standard are listed in Appendix A
of the Standard. Currently, there are
over 70 ATDs listed including:
- Hepatitis B, C, & D;
- Tuberculosis;
- Pneumonia;
- SARS;
- Herpes;
- H1N2;
- Measles;
- Mumps;
- Salmonella; and
- Novel or unknown
4. How can I reasonably control the exposure of ATD’s in an ambulance setting?
A. Obviously, not all patients can be pre-screened for an ATD in an
emergency setting. A policy needs to be developed so that whenever possible,
pre-screening procedures are in place. If an ATD is known or suspected and
the patient cannot be masked, both the driver and attendant will have to don
the applicable Personal Protective Equipment unless it interferes with the
abilities of the driver and/or attendant in their duties.
5. What kind of masks is required by the Standard?
A. There are three types of masks:
- Patient mask (commonly referred to as a surgical mask)
- N95 Mask or higher
- PAPR (Powered Air Purifying Respirator)
Effective September 1, 2010, the employer shall provide a powered air purifying respirator (PAPR) with a High Efficiency Particulate Air (HEPA) filter(s), or a respirator providing equivalent or greater protection, to employees who perform high hazard procedures on ATD cases or suspected ATD cases unless the employer determines that this use would interfere with the successful performance of the required task or tasks.
The N95 mask is considered by Cal OSHA as a "respirator," thus requiring employers
to have a "Respirator Protection Program" in place. One of the most important
parts of a "Respirator Protection Program" is the "Fit-Test," which is required
initially and annually (two years for employees who are not exposed to high
hazard procedures). The Fit-Test also will require a medical examination.
6. As an employer, what are my requirements to protect my employees?
A. As an employer, you must develop various written safety plans by law, including your Injury & Illness Prevention Program (IIPP), amongst others. As part of your IIPP, you will be required to have very important and integral "Programs" which would include a "Respirator Protection Program," "Aerosol Transmissible Diseases Exposure Control Plan," "Bloodborne Pathogen Program," and "Personal Protective Equipment" section dealing with other required safety equipment such as gloves, aprons, non-respirator type masks and safety glasses / splash proof goggles or shields
Under those various "Programs," you are required to provide a certain level of documentable training at various times throughout the employee’s employment, including when they are hired.
Under the "Aerosol Transmissible Diseases Exposure Control Plan," you will be required to provide a certain level of vaccinations and medical testing at times throughout the employee’s employment and especially is they are exposed to one of the ATDs.
Also, first responders have additional requirements including "Hazardous Waste Operations and Emergency Response" (HAZWOPER).
As with all of the "Plans," recordkeeping and documentation is required and essential.
7. As an employer, what liabilities
can I face?
A. Based upon previous enforcement
of the Bloodborne Pathogen Standard by Cal / OSHA, it is expected that if an
employer were cited for not having an ATD Program, it would be cited as a "serious
violation" with a fine not exceeding $25,000.00. This would not include
other fines for violations found such as not having an Injury & Illness Prevention
Program, which is a maximum fine of $5,000.00. Fines can be "stacked," so
they can add up quickly. These fines are based on whether and injury occurs
or not. If it could be proved that an employee died from the failure of the
employer to not protect the employee’s safety, the fines would go up significantly
and the owner of the practice could face criminal homicide charges. These fines
do not include any attorney fees or civil fines should an employer be sued
for wrongful death, etc.
In summary, there are many written safety plans required by Cal / OSHA for the medical industry. Employees are exposed to chemical, ergonomic injuries, transmissible disease and bloodborne pathogen exposures on a daily basis. Employers need to maintain effective and business specific safety plans to protect themselves from both civil and criminal lawsuits.
The Aerosol Transmissible Disease Standard is 48 pages in length (as compared to the Bloodborne Pathogen Standard of 27 pages) and is now being considered as a model for federal OSHA and Canadian OSHA to implement in the near future. With the increased exposure to the H1N1 virus, now is the time to start preparing for this regulation.
HRI AT THE FOREFRONT
We are leading the human resources industry in helping clients meet the "Aerosol Transmissible Disease Standard." Because no two offices or facilities are the same, we are providing FREE on-site appointments to discuss ATD requirements in detail, and determine what is needed to ensure compliance with this new law.
Additionally we can provide and assist employers with all Cal / OSHA-required safety programs for the medical industry.
We are at the forefront of the issues as they arise for our clients. We have expertise in employer issues and stay on top of developing laws, trends, and regulations, allowing you to focus on running your practice. Please call 925.556.4044 to set up your FREE appointment
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