On November 15, 1994, the Occupational Safety and Health Administration (OSHA) published in the Federal Register (59:58884-58956) the draft of a proposed revision of the Respiratory Protection Standard. One of OSHA's oldest standards, the Respiratory Protection Standard defines the conduct of the employer (eg, hospital) with respect to respirator training, fit testing, medical examinations, use, storage, and so on. The proposed revision appears to have been drafted with no consideration for its effect on healthcare workers or the healthcare industry. SHEA has prepared the following comments to OSHA, which have been submitted to the docket and will be presented at public hearings later this month.

We present basic information that a hospital epidemiologist needs when designing a surveillance system for noninfectious adverse outcomes of care. Specific topics reflect key characteristics of such a surveillance system: the purpose, rationale, priorities, definitions, data collection tools, data collection, analysis and reporting, and validation.

This final rule was made available to the public at the Government Printing Office in Washington, DC, on June 2, 1995. It was published in the Federal Register on June 8, 1995, in Part II of that issue (60 FR 110:30336). This rule addresses the National Institute for Occupational Safety and Health (NIOSH) and Department of Labor/Mine Safety and Health Administration (MSHA) certification requirements for respiratory protective devices. Specifically, the rule replaces MSHA regulations at 30 CFR Part 11 with new public health regulations at 42 CFR Part 84, while also upgrading testing requirements for particulate filters. Concurrent with NIOSH publication of this new rule, MSHA published a final rule to remove existing regulations at 30 CFR Part 11, which are made obsolete by this final rule. NIOSH now will have exclusive authority for testing and certification of respirators with the exception of certain mine emergency devices, which will continue to be jointly certified by NIOSH and MSHA.