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 systems 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 effective 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 laboratories and certifying organizations, and others engaged in ensuring the safety and effectiveness of PPT. Third, PPT end users must actively participate in the process by providing feedback based on experience in using 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 requisite 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 stipulate requirements for third-party testing and certification, where applicable, 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.
IOM (Institute of Medicine). 2008. Preparing for an influenza pandemic: Personal protective equipment for healthcare workers. Washington, DC: The National Academies Press.