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F. Respirators I. Respirator Use in Healthcare As noted in Grave Danger Section IV.A. of the preamble, it is wellaccepted that COVID19 might spread through airborne transmission during aerosol-generating procedures AGPs such as intubation. Moreover, outside of AGP scenarios, CDC has noted growing evidence that airborne droplets and particles can remain suspended in air,
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travel distances beyond 6 feet, and be breathed in by others CDC, May 13, 2021. Grave Danger Section IV.A. of the preamble notes studies showing that infectious viral particles have been collected at distances as far as 4.8
meters away from a COVID19 patient Lednicky et al., September 11, 2020, and airborne COVID19 infection has been identified in a Massachusetts hospital Klompas et al., February 9, 2021. Accordingly, the CDC
recommends the use of airborne Transmission Precautions, including the use of respirators, for any healthcare workers caring for patients with suspected or confirmed COVID19
CDC, March 12, 2020. This airborne transmission risk is in addition to the risks associated with contact and droplet transmission. Respirators have long been recognized as an effective and mandatory means of controlling airborne transmissible diseases and the use of this personal protective equipment is regulated under OSHAs Respiratory Protection standard 29 CFR
1910.134.
The CDC has issued core guidelines for when healthcare personnel should use respiratory protection against COVID19 infection see Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 COVID19 Pandemic CDC, February 23, 2021. These recommendations have been based on the most currently available information about COVID19, such as how the virus spreads, and are applicable to all healthcare settings in the U.S. In the guidance, the CDC defines healthcare settings as places where healthcare is delivered, including but not limited to:
acute care facilities, long-term acute care facilities, inpatient rehabilitation facilities, nursing homes, assisted living facilities, home healthcare, vehicles where healthcare is delivered e.g., mobile clinics, and outpatient facilities e.g., dialysis centers, physician offices.
In addition, the CDC provides examples of healthcare personnel, which include emergency medical service personnel, nurses, nursing assistants, home healthcare personnel, physicians, technicians, therapists, phlebotomists, pharmacists, students and trainees, contractual staff not employed by the healthcare facility, and persons not directly involved in patient care, but who could be exposed to infectious agents that can be transmitted in the healthcare setting e.g., clerical, dietary, environmental services, laundry, security, engineering and facilities
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management, administrative, billing, and volunteer personnel.
The CDC describes who is at greatest risk for COVID19 infection in a set of FAQs designed for healthcare workers CDC, March 4, 2021. In the FAQs, the CDC notes that those currently at greatest risk of COVID19 infection are persons who have had prolonged, unprotected close contact i.e., within 6
feet for a combined total of 15 minutes or longer in a 24 hour period with a patient with confirmed COVID19, regardless of whether the patient has symptoms. Moreover, according to the CDC, persons frequently in congregate healthcare settings e.g., nursing homes, assisted living facilities are at increased risk of acquiring infection because of the increased likelihood of close contact. In the FAQs, the CDC also reports that current data suggest that close-range aerosol transmission by droplet and inhalation, and contact followed by selfdelivery to the eyes, nose, or mouth are likely routes of transmission for COVID
19, and that long-range aerosol transmission, has not been a feature of the virus. The CDC further explains that potential routes of close-range transmission include splashes and sprays of infectious material onto mucous membranes and inhalation of infectious virions i.e., the active, infectious form of a virus exhaled by an infected person, but that the relative contribution of each of these is not known for COVID19.
As the CDC states in the FAQs CDC, March 4, 2021, although facemasks are routinely used for the care of patients with common viral respiratory infections, N95 filtering facepiece respirators or equivalent e.g., elastomeric half-mask respirators or higher-level e.g., full facepiece respirators or PAPRs respirators are routinely recommended to protect healthcare workers from emerging pathogens like the virus that causes COVID19, which have the potential for transmission via small particles. The CDC further advises that while facemasks will provide barrier protection against droplet sprays contacting mucous membranes of the nose and mouth, they are not designed to protect wearers from inhaling small particles. Because of this, the CDC
recommends the use of respirators for close-contact care of patients with suspected or confirmed COVID19. The CDC recommends that N95 filtering facepiece respirators FFRs and higherlevel respirators, such as other disposable FFRs, powered air-purifying respirators PAPRs, and elastomeric respirators, should be used when both barrier and respiratory protection is
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