On-the-Fly Compliance: How a Major Retailer Protected Workers During the Pandemic
By Ed Rutkowski
May 27, 2021—The first case of COVID-19 arrived in the United States on Jan. 21, 2020. Two weeks later, on Feb. 3, the U.S. declared a public health emergency. Around the time the World Health Organization officially declared a pandemic on March 11, most U.S. retailers had wholly or partially shut down.
Like many OEHS professionals, Benjamin Chandler felt that the rapid chain of events had put him on his heels. A board-certified industrial hygienist with GHD in Little Rock, Arkansas, Chandler provided EHS consulting services to a major retailer with a large geographic footprint whose business included pharmacies and optical centers, many of which were now closed. These facilities were vital sources of medications and healthcare services in communities across the country. It was Chandler’s responsibility to get them opened safely.
As he explained in a recorded presentation for Virtual AIHce EXP 2021, the scope of the project was daunting. The company’s healthcare business employed more than 5,000 people at more than 250 locations in each of the 48 contiguous states. Chandler needed to get these workers trained as quickly as possible on ever-shifting COVID-19 guidance in the middle of a pandemic while ensuring compliance with OSHA’s respiratory protection standard.
He had help from a small team of regional coordinators, all CIHs experienced with respiratory protection. The regional coordinators oversaw local trainers in their region. The trainers, about 150 OEHS professionals, were themselves given internal company training related to the project. They were responsible for conveying COVID-19 guidance to workers in the pharmacies.
The team’s main objectives were to develop an overall control and prevention program, distribute filtering facepiece respirators (FFRs) to employees, quickly identify all tasks requiring the use of respiratory protection, and establish appropriate fit-testing methods. Given the shortage of FFRs, Chandler’s team decided to use a qualitative fit-testing method to preserve respirators. Their final objective, establishing consistent procedures, was perhaps the most difficult to achieve due to the size of the workforce and the diversity of their job tasks.
Understanding the hazards facing healthcare providers and the tasks they were performing proved to be a challenge, Chandler said, due to the number of facilities spread across the country. Common tasks were sometimes performed slightly differently in different geographic areas.
The shortage of N95 FFRs meant that many types of alternative respirators were coming on the market. Each time Chandler’s team encountered a new device, they evaluated it to understand whether it was adequate for workers to use.
OSHA’s respiratory protection standard requires employers to perform medical evaluations to determine whether workers are able to wear respirators. Describing the challenge facing his team, Chandler asked, “How do you ultimately get 5,000 employees medially cleared for a respirator in a matter of weeks?” The team eventually settled on a virtual approach that included a questionnaire administered to employees through an app on their mobile devices and telemedicine—remote visits with medical professionals.
To properly document the project, the team used a customized digital application populated with information from employees’ medical clearances. This system helped shorten the turnaround time between medical clearance and fit testing; even better, it prevented employees who hadn’t been cleared from being fit tested. Employees were given a hard copy of their medical clearance, which they were required to produce when they arrived for fit testing. Those who didn’t have proof of medical clearance were turned away.
“Verifying that [medical clearances] were getting done in real time and having those records in a central database was critical,” Chandler said. Due to the system’s efficiency, employees who were medically cleared on a Monday could be fit tested on Wednesday and back to work on Thursday.
The system also allowed the team to easily update training materials so the trainers could keep up with shifting guidance. Employees were given copies of the training and their fit testing results.
Looking back on the project now, Chandler counts several successes. Chief among them were that 85 percent of employees passed their fit test and that the team kept inadequate respirators from reaching employees. “On this large a scale, to see that kind of pass rate was encouraging,” Chandler said. “We did see some equipment being proposed as effective solutions for N95 respirators when in fact they weren’t. We were able to discount those and prevent them from being included in this program.”
Ed Rutkowski is editor in chief of The Synergist.