Maintaining Your Respiratory Protection Program in LTC Centers: Actions and Frequencies

Long term care (LTC) centers must adhere to specific requirements for compliance with the Occupational Health and Safety Administration (OSHA) Respiratory Protection Standard (29 CFR 1910.134). The nature of airborne hazards, the presence of respiratory threats, the specific respiratory protection program, and the resulting compliance requirements will vary between organizations. Employers must recognize that once a Respiratory Protection Program (RPP) is established, ongoing maintenance is necessary to ensure compliance with the OSHA standard.

Navigating “Safety” in Long Term Care Centers: Separating the Roles of OSHA and the CMS requirements for Emergency Preparedness


In this third article regarding the connection between the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare & Medicaid Services (CMS) Life Safety and Emergency Preparedness (EP) Requirements, the focus will be on how OSHA’s regulations overlap with CMS’ EP requirements, found in 42 CFR 483.73 (Appendix Z).
It’s important to note that CMS’ EP requirements do NOT apply to assisted living, however any OSHA requirements do apply.

A Roadmap to OSHA Requirements = A Vital Guide for Long Term Care Providers

Understanding and adhering to Occupational Health and Safety Administration (OSHA) standards is a critical responsibility for long term care providers. To assist in this crucial task, AHCA/NCAL has released “A Roadmap to OSHA Requirements,” a comprehensive resource designed to simplify OSHA​regulations for providers.​

This roadmap is a practical guide, offering detailed insights into relevant OSHA standards and how they intersect with CDC guidelines and CMS requirements. The roadmap doesn’t just cover existing regulations; it also provides previews of upcoming OSHA changes that could impact long term care. This preview is essential for staying abreast of future regulatory requirements and maintaining a safe environment for your staff.

AHCA/NCAL’s roadmap is an invaluable tool for long term care providers seeking to navigate the complexities of OSHA compliance. It also underscores the long term care communities commitment to maintaining high standards of workplace safety and health.

Explore “A Roadmap to OSHA Requirements” to enhance your organization’s compliance and safety practices. Access this vital resource on the AHCA/NCAL website: A Roadmap to OSHA Requirements.​

Respiratory Protection in Long Term Care

Most long term care (LTC) centers had no need for respirators before the pandemic because any patients with airborne infectious diseases were transferred and cared for in appropriate and capable alternate facilities. Moving forward, however, respirators and the compliance obligations that come with them are now part of the expected infection control and employee safety programs in most LTC centers. Importantly, OSHA has an entire standard devoted to respirators, the Respiratory Protection Standard (29 CFR 1910.134). While the OSHA standard can be complicated and is highly dependent on the type of hazard and respirator used, the following highlights the basic requirements that affect most LTC centers.


Personal Protective Equipment, Hazard Assessment Standard, and the Hierarchy of Controls

The Hierarchy of Controls
When conducting a hazard assessment to determine PPE, it is important to understand that PPE is only one control measure. In fact, PPE is the last safety measure to consider as you see in the illustration below. In long term care, we use a mix of measures to minimize occupational hazards. In OSHA’s vocabulary, this mix is known as the “hierarchy of controls,”  which consists of FIVE levels: elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE).
The most effective measures are at the top of the hierarchy, with elimination and substitution being the preferred methods. These involve removing the hazard entirely or replacing it with something less hazardous. Engineering controls come next, focusing on designing and isolating hazards. Examples of such controls in LTC might be negative pressure rooms or barrier walls for protection against airborne infectious agents. Administrative controls involve changing work practices and policies, including infection control procedures and hand-washing protocols.