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OSHA says employers must protect temp workers from noise and respirator hazards


January 1, 2019

OSHA has released twin bulletins requiring staffing agencies and host employers to share responsibility for protecting temporary workers from respiratory and noise hazards as part of its Temporary Worker Initiative (TWI).

The bulletins, released in June 2018, do not specifically single out healthcare facilities, but many do act as host employers or rely on temp agencies for guest physicians and nursing staff. Many healthcare facilities and laboratories have multiple hazardous chemicals as well as loud environments that could affect a worker’s health and well-being.

The bulletins are the latest of several released under the TWI since its launch in 2013. In 2015 and 2016, OSHA released similar bulletins requiring host employers to provide bloodborne pathogen protection, hazard communications, PPE, injury and illness recordkeeping, and safety and health training.

What exactly is a host employer, and why does it have responsibility under the new guidance? According to OSHA, the host employer is typically most familiar with the chemicals present in the workplace and has control over the processes and equipment that may produce respiratory hazards to which temporary workers may be exposed.


  • The host employer is generally in the best position to implement a respiratory protection program, and these provisions will likely be in place for permanent staff.
  • The host employer can maintain the appropriate surveillance required given work area conditions and the degree of employee exposure.
  • The host employer is usually in the best position to reevaluate respirator use when changes occur in work area conditions, including production or process modifications that affect levels of employee exposure and physical stress that may affect respirator effectiveness. The host employer should communicate any changes to the respiratory protection program with the temporary employees and staffing agency.  

Both documents include sample scenarios that explore what could happen if workers do not receive adequate training or protection.

Respiratory protection

Also in 2015, OSHA released a guidance manual, entitled Hospital Respiratory Protection Program Toolkit: Resources for Respirator Program Administrators, a collaboration with the CDC and NIOSH that covers topics including why healthcare facilities need a respiratory protection program, the types of respirators and protection available, and how to develop a protection program in a facility.

The toolkit was the latest of several new manuals that OSHA has released in the last year and is likely an attempt to address statistics showing that healthcare workers suffer some of the highest rates of workplace injuries and illnesses in U.S. workplaces.

The new OSHA bulletin regarding host employers and temporary workers lays out the responsibilities and dangers of not providing proper protection.

“Respirators protect workers against insufficient oxygen environments and harmful air contaminants in dusts, fogs, fumes, smokes, mists, gases, vapors, and sprays,” the bulletin states. “Exposure to hazardous air contaminants could cause cancer, other serious diseases, and death. The primary goal of preventing employee exposures to hazardous air contaminants is to reduce the incidence of work-related diseases and death.”

According to OSHA, the agency’s Respiratory Protection Standard (1910.134) requires the use of appropriate respirators for general industry, construction, and maritime (1915.154, 1917.92, and 1918.102). Employers must identify and evaluate possible workplace respiratory hazards and determine the correct type of respirator.

“While both the host and the staffing agency are responsible to ensure that the employee is properly protected in accordance with the standard, the employers may decide that a division of the responsibility may be appropriate,” the bulletin states. “Neither the host nor the staffing agency can require workers to provide or pay for their own respiratory protection when it is required.”

As far as respiratory protections, the new bulletins specifically require that the host employer handle the following:

  • Evaluating exposure levels
  • Implementing and maintaining engineering, administrative, and work practice controls
  • Maintaining a respiratory protection program when respirators are required

The staffing agency, meanwhile, is required to take reasonable steps to ensure workers are protected from hazards and must communicate regularly with workers and the host employer.

If you’re curious about what steps to take to improve your respiratory safety program (or even start one), take some lessons from OSHA’s toolkit.

Some of the best features of the toolkit include a user-friendly description of the types of respirators, such as N95 and negative-pressure respirators, and the proper way to conduct a fit test on users. A technical, yet easy-to-understand explanation of the hazards present in hospitals and healthcare facilities is illustrated by photos that demonstrate, for example, the droplets that remain suspended in the air after someone sneezes. Informative graphics describe when users should wear certain types of respirators, and photos demonstrate what a proper fit should look like.

Another section covers developing a respiratory protection plan in the workplace, starting with how to conduct a hazard assessment of how likely you are to have a patient with an aerosol-transmitted disease (ATD). For instance, factors that should be considered include:

  • Who is exposed to suspected or confirmed cases of ATDs?
  • Who will greet and triage patients with ATDs?
  • Who will provide care for patients with ATDs?
  • Who will be performing aerosol-generating
  • procedures on patients with ATDs, on cadavers,or in laboratories?
  • Who will be cleaning the rooms of patients with ATDs?
  • Do you have contractors (e.g., those who service ventilation systems) or temporary workers in your facility who are reasonably anticipated to be exposed to patients or equipment that may be a source of ATD pathogens?
  • Who will be designated as a first receiver of victims exposed to unknown radiological, biological, or chemical agents?

Hearing protection

According to OSHA estimates, about 30 million people in the U.S. are exposed to hazardous noise on the job, and hearing loss has been considered one of the prevalent worker health concerns for more than 25 years. Since 2004, the Bureau of Labor Statistics has reported that nearly 125,000 workers have suffered significant, permanent hearing loss. In 2009 alone, BLS reported more than 21,000 hearing loss cases.

OSHA’s second bulletin examines compliance with OSHA’s Occupational Noise Standard (1910.95) for general industry and construction. Again, don’t think healthcare facilities are exempt. OSHA ensures workers’ rights to a safe workplace, and if an inspector notices that your workplace is too noisy, or if a worker makes a complaint against you, you could be faced with debilitating fines, or worse: workers’ compensation costs for lifelong injuries that can’t be reversed using medicine or surgery.

The OSHA directive directs the host employer to determine noise exposure levels; implement and maintain engineering, administrative, and work practice controls; provide appropriate hearing protection; and maintain a hearing conservation program.

The staffing agency is required to ensure the following:

  • Maintain familiarity with established noise exposure hazards and controls
  • Inform workers of potential hazards and ensure that they have adequate hearing protection
  • Communicate regularly with workers and host employers about noise exposures

“Neither the host nor the staffing agency can require workers to provide or pay for their own hearing protection devices or require workers to purchase such devices as a condition of employment or placement,” the bulletin states. “In addition, employees must be paid for the time spent receiving their audiograms, and the audiograms must be at no cost to the employee.”

Employers must initiate a valid baseline audiogram within six months of a worker’s first exposure at or above a time-weighted average of 85 decibels (dBA) over an eight-hour period for general industry and 90 dBA for construction, according to the bulletin.

Below are some recommendations from OSHA to help you reduce the amount of noise in your facility. For more information, check out the OSHA webpage.

Engineering controls. These are things you can do around the workplace to help reduce noise; they may involve modifying or replacing equipment, or making physical changes along the path from the noise source to the worker’s ears. Some examples:

  • Choose low-noise tools and machinery, or place them on damping pads with springs that reduce vibration
  • Maintain and lubricate machinery and equipment (e.g., oil bearings)
  • Place a barrier between the noise source and employee (e.g., glass sound walls or curtains)
  • Enclose or isolate the noise source
  • Provide ear plugs or headphones that can reduce noise exposure

Administrative controls. These are changes to the workplace culture, policies, or rules that can reduce exposure to loud noise. Examples include:

  • Operating noisy machines only during shifts when fewer people are exposed.
  • Limiting the amount of time a person spends at a noise source.
  • Providing quiet areas where workers can gain relief from hazardous noise sources (e.g., constructing a soundproof room where workers' hearing can recover—depending upon their individual noise level and duration of exposure, and time spent in the quiet area).
  • Restricting worker presence to a suitable distance away from noisy equipment.

Controlling noise exposure through distance. This is often an effective, yet simple and inexpensive administrative control. This control may be applicable when workers are present but are not actually working with a noise source or equipment. In open space, for every doubling of the distance between the source of noise and the worker, the noise is decreased by 6 dBA.

Hearing conservation programs. Since 1981, OSHA has required employers to implement a testing and conservation program in any workplace where workers may be routinely exposed to an average of 85 dBA or more over an eight-hour period. Your responsibilities as an employer include the following:

  • Workplace noise sampling, including personal noise monitoring to identify which employees are at risk from hazardous levels of noise
  • Informing at-risk workers of the results of their noise monitoring
  • Providing affected workers or their authorized representatives with an opportunity to observe any noise measurements conducted
  • Maintaining a worker audiometric testing program (hearing tests), which is a professional evaluation of the health effects of noise upon an individual worker’s hearing
  • Implementing comprehensive hearing protection follow-up procedures for workers who show a loss of hearing (standard threshold shift) after completing baseline (first) and yearly audiometric testing
  • Proper selection of hearing protection, based upon individual fit and manufacturer’s quality testing indicating the likely protection that a properly trained wearer will gain
  • Evaluate the hearing protector’s attenuation and effectiveness for the specific workplace noise
  • Training and information that ensures the workers are aware of the hazard from excessive noise exposures and how to properly use the protective equipment that has been provided
  • Data management of and worker access to records regarding monitoring and noise sampling

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