Release of National Academies Consensus Study Report on Protecting Workers and the Public from Inhalation Hazards
This month, the National Academies of Sciences, Engineering, and Medicine published a Consensus Study Report titled, Frameworks for Protecting Workers and the Public from Inhalation Hazards. Federal partners, NIOSH, the Environmental Protection Agency (EPA) and the Department of State, as well as the CDC Foundation, commissioned this report to address the evolving respiratory protection needs of the public and workers not operating under a respiratory protection program (RPP).
When employers can identify inhalation hazards in advance–such as viruses, wildfire smoke or mold–they can protect their workers with an RPP. The Consensus Study Report recommends a framework that can provide a unified and authoritative source of information for the effective oversight of the development, approval and use of respiratory protection for the public and workers not protected by an RPP.
To this point, the federal government has exclusively directed its oversight of respiratory protection in the United States to occupational settings where hazards are defined as part of an RPP and appropriate NIOSH-approved respiratory protection is provided. These RPPs exist within workplaces where the Occupational Safety and Health Administration (OSHA) is the governing authority and regulations apply under the Occupational Safety and Health Act of 1970. Within these programs, workers undergo medical clearance, fit testing and training on how to properly use their respiratory protective devices.
However, independent contractors, self-employed workers and “gig” workers are not considered either employees or employers, and therefore they are not covered by OSHA requirements. As a result, according to this framework, the respiratory protection needs of many workers are not being met, particularly those in low-paying positions, people with disabilities and those with limited English proficiency, among other groups that are at increased risk of exposure to inhalation hazards.
Similarly, natural disasters and other public health concerns like infectious diseases have increasingly lead the public to search for guidance on the use and value of respiratory protection. While OSHA has the primary oversight for respiratory protection use and NIOSH is charged with testing and approving all respirators used within RPPs, their authorities remain limited to occupational settings. There is no formal system for coordinating the development and distribution of guidance to state and local health agencies or the public. Therefore, a new paradigm must be created to support the most effective use of respiratory protection for the public and workers who may not be adequately protected.
The report recognizes the need for an organization to coordinate these efforts and for ongoing improvement to both known specific inhalation hazards and on emergency and national preparedness. No matter the setting, it should be noted that efforts towards reducing an inhalation hazard at the source through engineering, administrative and other controls should always be the first consideration.
The report’s recommendations are housed within seven core functions for both expanded occupational use and for personal use of respiratory protective devices by the public. Recommendations include speeding up NIOSH’s respirator conformity assessment process by using recognized consensus standards and third-party laboratory testing, establishing comprehensive workplace exposure standards to trigger respiratory protection program requirements and establishing and standardizing a process to determine the public’s need for respiratory protection.
The report also notes the need to revise Occupational Safety and Health Act to clarify the definitions of employer and employee so that OSHA has the authority necessary to ensure respiratory protection for all types of workers.
This blog was co-authored in partnership with the National Institute for Occupational Safety & Health.
Maryann M. D’Alessandro, PhD, is the Director of the NIOSH National Personal Protective Technology Laboratory. Jaclyn Krah Cichowicz, MA, is a Health Communications Specialist for the NIOSH National Personal Protective Technology Laboratory.
