Port Notes - Pandemic Safety and the Hierarchy of Controls

From the desk of Captain Jeffrey Monroe, MM, AMPE

OSHA, the CDC, the World Health Organization, as well as local health units have developed good guidelines for developing policies and plans to meet the challenges of illness, whether seasonal flu or widespread pandemic challenges. For most employers, protecting their employees will depend on emphasizing proper hygiene (disinfecting hands and surfaces) and practicing social distancing. All employers should implement good hygiene and infection control practices. According to OSHA, occupational safety and health professionals use a framework called the "Hierarchy of Controls" to select ways of dealing with workplace hazards. The Hierarchy of Controls prioritizes intervention strategies based on the premise that the best way to control a hazard is to systematically remove it from the workplace, rather than relying on employees to reduce their exposure. In the setting of a pandemic, this hierarchy should be used in concert with current public health recommendations. The types of measures that may be used to protect yourself, your employees, and your customers (listed from most effective to least effective) are: engineering controls, administrative controls, work practices, and personal protective equipment (PPE). Most employers will use a combination of control methods. There are advantages and disadvantages to each type of control measure when considering the ease of implementation, effectiveness, and cost. For example, hygiene and social distancing can be implemented relatively easily and with little expense, but this control method requires employees to modify and maintain their behavior, which may be difficult to sustain. On the other hand, installing clear plastic barriers or a drive-through window will be more expensive and take a longer time to implement, although in the long run may be more effective at preventing transmission during a pandemic. Employers must evaluate their particular workplace to develop a plan for protecting their employees that may combine both immediate actions as well as longer term solutions. Some of these controls include: Work Practice and Engineering Controls - Historically, infection control professionals have relied on personal protective equipment (for example, masks and gloves) to serve as a physical barrier in order to prevent the transmission of an infectious disease from one person to another. This reflects the fact that close interactions with infectious patients is an unavoidable part of many occupations. The principles of industrial hygiene demonstrate that work practice controls and engineering controls can also serve as barriers to transmission and are less reliant on employee behavior to provide protection. Work practice controls are procedures for safe and proper work that are used to reduce the duration, frequency or intensity of exposure to a hazard. When defining safe work practice controls, it is a good idea to ask your employees for their suggestions, since they have firsthand experience with the tasks. These controls should be understood and followed by managers, supervisors and employees. When work practice controls are insufficient to protect employees, some employers may also need engineering controls. Engineering controls involve making changes to the work environment to reduce work-related hazards. These types of controls are preferred over all others because they make permanent changes that reduce exposure to hazards and do not rely on employee or customer behavior. By reducing a hazard in the workplace, engineering controls can be the most cost-effective solutions for employers to implement. During a pandemic, engineering controls may be effective in reducing exposure to some sources of pandemic influenza and not others. For example, installing sneeze guards between customers and employees would provide a barrier to transmission. The use of barrier protections, such as sneeze guards, is common practice for both infection control and industrial hygiene. However, while the installation of sneeze guards may reduce or prevent transmission between customers and employees, transmission may still occur between coworkers. Therefore, administrative controls and public health measures should be implemented along with engineering controls. Examples of work practice controls include:

  • Providing resources and a work environment that promotes personal hygiene. For example, provide tissues, no-touch trash cans, hand soap, hand sanitizer, disinfectants and disposable towels for employees to clean their work surfaces.

  • Encouraging employees to obtain a seasonal influenza vaccine (this helps to prevent illness from seasonal influenza strains that may continue to circulate).

  • Providing employees with up-to-date education and training on influenza risk factors, protective behaviors, and instruction on proper behaviors (for example, cough etiquette and care of personal protective equipment).

  • Developing policies to minimize contacts between employees and between employees and clients or customers.

Examples of engineering controls include:

  • Installing physical barriers, such as clear plastic sneeze guards.

  • Installing a drive-through window for customer service.

  • In some limited healthcare settings, for aerosol generating procedures, specialized negative pressure ventilation may be indicated.

Administrative Controls - Administrative controls include controlling employees' exposure by scheduling their work tasks in ways that minimize their exposure levels. Examples of administrative controls include:

  • Developing policies that encourage ill employees to stay at home without fear of any reprisals.

  • The discontinuation of unessential travel to locations with high illness transmission rates.

  • Consider practices to minimize face-to-face contact between employees such as e-mail, websites and teleconferences. Where possible, encourage flexible work arrangements such as telecommuting or flexible work hours to reduce the number of your employees who must be at work at one time or in one specific location.

  • Consider home delivery of goods and services to reduce the number of clients or customers who must visit your workplace.

  • Developing emergency communications plans. Maintain a forum for answering employees' concerns. Develop internet-based communications if feasible.

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