This post is based on a presentation given at AIHce EXP 2021 by Steven Lipson. It is the first in the “Essentials of Pandemic Response” series based on AIHA's recently published ebook.

Steven A. Lipson, CIH, CSP, opened his 2021 AIHce EXP presentation—titled “COVID-19 Response: Inventing a New Science”—by narrating what he termed “the story of the red X.” In this story, a plant is shut down due to a noxious odor. The employees on site do not know where the odor is coming from or what may be malfunctioning, and every additional hour that the plant remains shut down costs the owner a great deal of money. A consulting industrial hygienist (IH) is called in, who walks the facility’s floor, sniffs the air, and approaches a panel on a column. The IH marks the panel with a red “X” and informs the manager that the problem will be found behind that panel—and on investigation, the IH turns out to be correct.

Then the IH charges the plant owner $25,000 for a 10-minute visit, explaining on the invoice that while placing a red X on a panel does not take much time, an IH’s expertise is invaluable.

“Indoor air quality,” said Lipson, “is pretty easy most of the time.” He explained that once the source of an IAQ problem is determined, the fix is often simple, involving source removal, the implementation of engineering modifications, or—if the former kinds of remediation aren’t feasible—the use of personal protective equipment (PPE) by exposed workers. But protecting his clients from COVID-19 was different.

The goal of the presentation was to inform the audience of the initial response by IHs and others in the occupational and environmental health and safety (OEHS) community to an unknown hazard and how they modified their approaches as new data became available.

The Challenges of a New Hazard

Lipson, a principal scientist with consulting firm NV5 Inc., began to receive calls from clients concerned about COVID-19 in February and March 2020. Initially, he was not sure how his services could help them. In the early days of the pandemic, when much was still unknown about SARS-CoV-2, it seemed to him as if the hazard could not be mitigated using the traditional hierarchy of controls: elimination of the hazard, substitution of the hazard, application of engineering controls, application of administrative controls, and the use of PPE. Solutions relying on elimination or replacement of the source of the virus were difficult to implement because the source was people, including his clients’ employees and customers. At this date, OEHS professionals were not sure what engineering and administrative controls they could recommend that their clients use to effectively control the virus. Information about PPE was conflicting at that time, with CDC cautioning consumers against using disposable face masks and N95 respirators, not because these measures weren’t effective but because supplies were limited and had to be reserved for doctors and healthcare workers.

In typical circumstances, OEHS professionals rely on previously established data to recommend controls that decrease hazard levels to the point that workers are likely to be safe. At the pandemic’s onset, however, OEHS professionals could not recommend controls based on previously established data, existing standards, or occupational exposure levels dealing with COVID-19. For example, Lipson felt he could not recommend an engineering control that would involve diluting indoor air until a “safe” concentration of airborne SARS-CoV-2 viral particles was attained because he didn’t know what a “safe” concentration would be or whether dilution would be effective at reaching it. Also, at the time, there were no means of measuring airborne or surface concentrations of the virus.

Moreover, the Code of Ethics for the Professional Practice of Industrial Hygiene, adopted in 1995 by the American Board of Industrial Hygiene, ACGIH, and AIHA, stated that IHs should “perform services only in the areas of their competence.” (While this code of ethics has been replaced with more current versions, these codes share this sentiment.) As COVID-19 was a completely new hazard, OEHS professionals like Lipson were not sure that it was ethically or legally defensible to consult their clients on controlling it.

Applying Previous Expertise and Developing New Strategies

A breakthrough came when the general manager of a professional baseball team called Lipson not to ask for consultation on controlling COVID-19 directly but to request a cleaning protocol for bodily fluids in locker rooms. While Lipson didn’t know at the time how to address COVID-19, he did know how to decontaminate viral loads on surfaces and could offer the general manager advice on this matter. This led Lipson to realize that much of his expertise was useful when applied to the new hazard: he already possessed a skill set in the areas of cellular biology, the use of chemicals for cleaning and disinfecting, ventilation, epidemiology, fluid dynamics and the spread of aerosols, selecting proper PPE, and targeting his recommendations to his clients’ needs. Lipson called back his other clients.

Still, there was much that Lipson didn’t know, and he had to navigate these gaps in his knowledge. During a site walkthrough at one client’s building, he noticed a worker cleaning the stairs of an escalator. Lipson considered recommending for the worker to focus on cleaning the escalator handrail instead, until it occurred to him that SARS-CoV-2 might also be transmitted on the soles of people’s shoes. (At the time, it was not yet clear that the virus is more likely to be transmitted via the air than through contact with surfaces.) This was one instance when Lipson was aware that there was much he did not know and that this was a hazard no OEHS professional had encountered before.

In addressing it, Lipson found that many of his approaches for controlling previous hazards needed to be adapted. At first, he wrote aggressive cleaning protocols for his clients. He toured facilities and produced technical 25-page specifications for clients’ use. Then he learned that most clients were not hiring abatement professionals to clean and disinfect their facilities but janitorial staff who could not understand the technical documents. Accordingly, he began rewriting the technical specification documents in short paragraphs that explained, in simple language, what surfaces to disinfect and how to effectively do so. Then he converted the short, simple paragraphs into checklist form, similar to how restaurants detail opening and closing procedures. The checklist format also allowed clients and their employees to record when a disinfection procedure had last been performed and by whom.

Practicing OEHS During a Pandemic

Lipson also encountered challenges related to travel restrictions and social distancing protocols. Unable to visit a client in Vancouver, Canada, he redirected the client to an IH based in that city. Some clients were wary of strangers, including visiting OEHS professionals and abatement or cleaning professionals, entering their facilities and potentially spreading the virus.

When CDC produced new guidance for preventing COVID-19 or changed existing guidance, Lipson had to interpret it on behalf of his clients. At a time when respirator supplies were stretched thin, clients’ questions with respect to CDC guidelines included what PPE should be used and whether face coverings should be worn or not. Lipson initially recommended the use of N95 respirators, at minimum, and to be wary of KN95s.

Other challenges Lipson encountered while practicing OEHS during the pandemic, particularly during its earliest months, included:

• the potential of legal liability for Lipson and his clients as they worked in dangerous circumstances and with a limited understanding of the hazard
• the need to develop ventilation controls tailored to every facility, using ultraviolet germicidal irradiation, filters with certain minimum efficiency reporting value (MERV) ratings, and the use of high-efficiency particulate air (HEPA) filters
• contractors who offered clients preventative measures not guaranteed to be effective against SARS-CoV-2
• the difficulty of “clearing” areas as clean of SARS-CoV-2 viral particles, such as by determining an acceptable viral load—after polymerase chain reaction (PCR) testing for SARS-CoV-2 became available in June 2020
• the need to provide training, PPE, medical evaluations, and other preparations for workers performing cleaning and disinfecting routines, following OSHA’s standard for respiratory protection, 29 Code of Federal Regulations 1910.134
• the selection of cleaning and disinfecting chemicals effective against SARS-CoV-2
• widespread misinformation about the virus and its transmission

IHs like Lipson had to navigate challenges such as these and many others as they attempted to protect workers’ health and safety in unprecedented circumstances, far outside of their pre-pandemic daily routines, while adhering to familiar frameworks—such as the hierarchy of controls—and ethical principles. Effectively, the knowledge and strategies that OEHS professionals have generated and are continuing to build upon during the pandemic are creating the new science of COVID-19 response. This science is still developing, and even when the virus is no longer a severe hazard, unintended consequences stemming from the pandemic and its immediate response will need to be addressed. OEHS professionals are already aware of some of the potential issues, including the possibility for mold and Legionella to colonize unoccupied buildings and the appearance of health effects resulting from elevated exposures to volatile organic compounds in chemicals used for cleaning and disinfecting.

Moreover, the OEHS community must prepare for the next pandemic: for as long as viruses can threaten human health, there will be a need for those who know how to make workplaces and communities safe again.

Resources:

AIHA: “COVID-19 Response: Inventing a New Science,” AIHce EXP 2021 (virtual presentation by Steven A. Lipson, May 24, 2021).