[MCOH-EH] contractors and respiratory protection

[Auerbach, Karl]

Agree than many contract groups don’t really comply as they should.  And even with the contract language being “strong”, you really don’t know or can control how well they comply.

In these “new” contracts- who wanted the lack of your group doing at least some of the compliance?   Your parent organization perhaps  to save money and avoid liability  or the contracting agency?

Do you monitor actual use of the respirators in contract staff?  How do you do that?  What do you do with non-compliance within the physical bounds of your institution?   Has your institution considered liability of someone (in this case a non employee, getting injured due to non compliance  and hence a real possible third party lawsuit against your institution.  What if the contractor group didn’t comply and the person is injured in your institution.  Sure its workers’ comp for the contractor but its not for you since you are not the employer.

Just my opinion, nothing more…

Karl Auerbach MD
Albany, NY



From: MCOH-EH <mcoh-eh-bounces at mylist.net> On Behalf Of Mullinax, Ross A CDR USN DHA PORTSMOUTH NMC (USA) via MCOH-EH
Sent: Tuesday, June 27, 2023 4:00 PM
To: MCOH-EH <mcoh-eh at mylist.net>
Cc: Mullinax, Ross A CDR USN DHA PORTSMOUTH NMC (USA) <ross.a.mullinax.mil at health.mil>
Subject: [EXTERNAL] [MCOH-EH] contractors and respiratory protection

All, Our organization has previously provided limited services to contract staff, including respirator exams and fit testing with the masks we have in inventory at our facilities, a single bloodborne pathogen exposure visit (in addition to

All,

Our organization has previously provided limited services to contract staff, including respirator exams and fit testing with the masks we have in inventory at our facilities, a single bloodborne pathogen exposure visit (in addition to the emergency evaluation immediately after the incident), and annual flu shots.  The new contracts are being written so that we provide essentially nothing to contract staff, and everything is the responsibility of the contracting agency.  In Occ Health we do a review of all contractor medical packages when they start, to ensure compliance with healthcare worker requirements and make sure that they aren’t missing something (which they frequently are, such as an immunization or a QFT).  For others that do this at their institution, how are you validating that they are complying with the terms of their contract with regard to respiratory protection?

Are they provided with a list of masks available at your institution and asked to fit test with one from that list?
Are they just asked to fit test wherever they want and bring their own personal masks with them?
Are they just informed what the masks are at your facility, then let the contracting agency figure it out?

I have low confidence that the contracting agencies will due their due diligence to ensure their employees are protected in our facilities.  Looking to do what we can within the language of our written contract agreements to help ensure that our contract staff are adequately protected.  Appreciate any thoughts or advice that others may have on this issue.

V/r,

Ross A. Mullinax, MD, MPH
CDR, MC, USN
Director for Public Health
Head, Occupational and Environmental Medicine
Naval Medical Center Portsmouth

Email: ross.a.mullinax.mil at health.mil<mailto:ross.a.mullinax.mil at health.mil>
Tel: 757-953-9703


V/r,

Ross A. Mullinax, MD, MPH
CDR, MC, USN
Director for Public Health
Head, Occupational and Environmental Medicine
Naval Medical Center Portsmouth

Email: ross.a.mullinax.mil at health.mil<mailto:ross.a.mullinax.mil at health.mil>
Tel: 757-953-9703

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