7
Toward a Comprehensive Approach to Safe and Effective PPT for Workers

As noted throughout this report, there are currently a number of inconsistencies in the nature and rigor of the conformity assessment processes that personal protective technologies (PPT) are required to meet in the United States. To ensure that workers are using PPT that meets required standards, the committee has recommended that the National Institute for Occupational Safety and Health’s (NIOSH’s) National Personal Protective Technology Laboratory (NPPTL) work with other agencies, standards and certifying organizations, end users, and others to develop and implement a tiered risk-based approach that would categorize various types of PPT and apply consistent conformity assessment requirements. From the committee’s perspective, this tiered approach has the advantage of addressing all types of non-respirator PPT and raising the quality of PPT conformity assessment. Although implementing this approach will be a major effort, it will incentivize non-respirator PPT developers and manufacturers to innovate and develop new products and technologies expeditiously to further enhance worker safety and health. This commitment to improve non-respirator PPT by strengthening the conformity assessment processes also necessitates an equally strong commitment to training and use of PPT. Equipment that successfully passes the conformity assessment process will not protect the worker if the selection and fit are incorrect, the PPT is not provided by the employer, or the PPT is used improperly.

The rapid entry of certified products and technologies into the marketplace and workplace is critical, especially during events such as the recent novel H1N1 influenza pandemic. While federal agencies have processes in place for emergency authorizations to rapidly approve products for deployment in such situations, the proposed comprehensive ap-



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7 Toward a Comprehensive Approach to Safe and Effective PPT for Workers As noted throughout this report, there are currently a number of in- consistencies in the nature and rigor of the conformity assessment processes that personal protective technologies (PPT) are required to meet in the United States. To ensure that workers are using PPT that meets required standards, the committee has recommended that the Na- tional Institute for Occupational Safety and Health’s (NIOSH’s) National Personal Protective Technology Laboratory (NPPTL) work with other agencies, standards and certifying organizations, end users, and others to develop and implement a tiered risk-based approach that would categor- ize various types of PPT and apply consistent conformity assessment requirements. From the committee’s perspective, this tiered approach has the advantage of addressing all types of non-respirator PPT and raising the quality of PPT conformity assessment. Although implementing this approach will be a major effort, it will incentivize non-respirator PPT developers and manufacturers to innovate and develop new products and technologies expeditiously to further enhance worker safety and health. This commitment to improve non-respirator PPT by strengthening the conformity assessment processes also necessitates an equally strong commitment to training and use of PPT. Equipment that successfully passes the conformity assessment process will not protect the worker if the selection and fit are incorrect, the PPT is not provided by the em- ployer, or the PPT is used improperly. The rapid entry of certified products and technologies into the mar- ketplace and workplace is critical, especially during events such as the recent novel H1N1 influenza pandemic. While federal agencies have processes in place for emergency authorizations to rapidly approve prod- ucts for deployment in such situations, the proposed comprehensive ap- 125

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126 CERTIFYING PERSONAL PROTECTIVE TECHNOLOGIES proach to risk analysis and conformity assessment will eliminate the need to operate in a crisis mode that could inadvertently lead to the entry of unsafe products into the marketplace. Adopting a systems approach to conformity assessment for non-respirator PPT will complement the sys- tems approach to PPT design and development recommended in a prior IOM report (IOM, 2008) and will also lead to an integrated system for certifying and regulating PPT. What will it take to make this change happen? First, government agencies, employers, workers, and other stakeholders must recognize that improving the health and safety of workers is of critical importance and impacts both economic and national security. For example, the shortage of healthcare workers during an influenza pandemic (due to lack of ef- fective PPT or other reasons) can negatively impact the nation’s health, productivity, and security. Second, adequate resources and staffing will be required of relevant government agencies, labor and manufacturing organizations, standards-setting organizations, third-party testing labora- tories and certifying organizations, and others engaged in ensuring the safety and effectiveness of PPT. Third, PPT end users must actively par- ticipate in the process by providing feedback based on experience in us- ing PPT in work and emergency situations. Fourth, demand for certified products needs to be made evident. Professional organizations specific to various occupations (e.g., the Joint Commission) must reinforce the re- quisite conformity assessment processes for products used by workers in those fields. Government and private-sector contracts need to specify that PPT used in that work must meet performance criteria. Finally and most importantly, regulatory requirements will largely drive whether change occurs. Occupational Safety and Health Administration (OSHA) and Mine Safety and Health Administration (MSHA) regulations that stipu- late requirements for third-party testing and certification, where applica- ble, can provide the impetus to drive the change that will result in a more consistent, comprehensive, and risk-based approach to PPT conformity assessment. The goal is ensuring and maintaining a safe and healthy workforce. REFERENCE IOM (Institute of Medicine). 2008. Preparing for an influenza pandemic: Per- sonal protective equipment for healthcare workers. Washington, DC: The National Academies Press.