This guidance summarizes how organizations should consider and manage preservation of their personal protective equipment (PPE) needs while ensuring the protection of workers during the coronavirus (COVID-19) pandemic response.
The strategies described in this document are focused on filtering facepiece respirators but can be applied to other types of PPE. Strategies for addressing shortages of PPE, to ensure protection against COVID-19 for healthcare workers, first responders and patients, revolve around three pillars of practice: reduce, reuse and repurpose. Industries that use PPE similar to what is needed in healthcare and emergency response operations (e.g., gloves, gowns, surgical masks, face shields, N95 respirators) as part of their normal duties may face challenges in obtaining PPE while available supply is prioritized for healthcare workers and first responders. Industries in which essential critical infrastructure workers need PPE to perform their duties should continue working with suppliers to acquire needed PPE, but should expect shortages to continue. All industries should immediately implement strategies to conserve and appropriately manage existing supplies of PPE and find alternative methods to address shortfalls and reduce the need for PPE in general. This is especially true for filtering facepiece respirators, such as N95 respirators, that have seen an extreme increase in demand across all sectors.
Strategies for Non-Healthcare Settings
In all work settings, PPE should be the final mechanism for protecting workers against occupational exposure to SARS-CoV-2, the virus that causes COVID-19. Employers should implement a hierarchy of controls to protect workers in ways that reduce reliance on PPE.
If possible, consider suspending or delaying operations for which PPE would ordinarily be required, including non-essential tasks in otherwise essential workplaces. Employers must implement engineering and administrative controls, if feasible, to protect workers before relying on PPE.
- Implement engineering controls, such as physical barriers (e.g., plexiglass barriers) and improved ventilation systems).
- Also implement administrative controls and safe work practices, such as adjusting business operations to increase physical space between employees.
- Consult the Center for Disease Control and Prevention (CDC) Interim Guidance for Businesses and Employers to Plan and Respond to COVID-19 and the U.S. Department of Labor and U.S. Department of Health and Human Services’ Guidance on Preparing Workplaces for COVID-19 for further considerations to reduce overall risk of exposure in the workplace.
- Follow CDC guidance on use of cloth face coverings in public settings along with other social distancing measures. Cloth face coverings can help contain infectious droplets and prevent wearers from spreading COVID-19 to others but are not a substitute for PPE where such equipment is needed to protect workers from exposure to the virus or other hazards. Cloth face coverings in combination with social distancing can help minimize exposure to infectious droplets spread when an infected person talks, exhales, coughs or sneezes.
- Alternate protective material not considered PPE, such as commercially manufactured cloth face coverings, may also be in short supply; demand has increased as Americans heed the U.S. government’s recent recommendation for their use as a complementary measure to the President’s Coronavirus Guidelines for America, 30 Days to Slow the Spread. If commercially sourced cloth face coverings are not available, they can be fashioned from common materials at low cost. Follow CDC’s guidance on how to make and use cloth face coverings.
When employers must provide PPE to workers whose routine duties require its use under the Occupational Safety and Health Administration (OSHA) PPE standards and regulations, or other laws or regulations, consider ways to:
- Consult guidance from CDC’s National Institute for Occupational Safety and Health (NIOSH) on strategies to conserve, extend, and respond to shortages in the supply of filtering facepiece respirators used in non-healthcare worksites, such as manufacturing and construction.
- Extend use times of undamaged, non-visibly soiled PPE, and implement expanded facility-based PPE reuse policies and procedures, including in accordance with OSHA and Centers for Disease Control and Prevention (CDC) guidance for extended use, re-use, and decontamination of various types of equipment.
- Understand and track PPE requirements and burn rates. Utilize CDC’s PPE burn rate calculator if you lack an existing means to do so.
- Use alternative types or sources of non-PPE protective materials to support necessary operations. Monitor the OSHA websites for updates and announcements on guidance documents outlining enforcement discretion policies. As of the date of this fact sheet’s publication, OSHA is allowing temporary enforcement discretion for the use of NIOSH-approved respirators that are beyond their manufacturer’s recommended shelf life, extended use and re-use of respirators in accordance with the CDC/NIOSH recommendations, and respiratory protection equipment certified under standards of other countries or jurisdictions.
- Consult OSHA’s enforcement guidance, which includes information about enforcement discretion around required annual fit testing of respirators for industries outside of healthcare.
All industries should follow U.S. Government guidance that enables critical infrastructure workers, when appropriate, to quickly return to work after potential exposure to someone with COVID-19, provided those workers are symptom-free and the workplace adheres to the recommended safety practices.
Acquiring PPE During Shortages
When essential critical infrastructure workers need PPE to perform their duties, and employers have implemented the hierarchy of controls and taken other measures to reduce the reliance on and burn rate of PPE, organizations should:
- Continue working with normal and alternate private sector suppliers to obtain PPE. It may be necessary to identify multiple options for suppliers and prioritize near-term versus long-term needs.
- If suppliers are unable to meet your needs, and the PPE is urgently required, submit a request for assistance to your local, territorial or state emergency management agencies. If local emergency management is unable to address the PPE shortfall, they can relay it to the state. If the state is unable to address it, they can submit a request for support to their FEMA Regional Response Coordination Center.
- Organizations should also report to the National Center for Disaster Fraud any instances of counterfeit or fraudulently labeled PPE, as well as any instances of hoarding or price gouging relating to PPE.
Any requests to local, state, or federal agencies for urgent re-supply of PPE for essential critical infrastructure workers should accurately describe:
- Specific types, quantities (include 30, 60 and 90-day demand), and locations where PPE is needed;
- Estimated time until shortage impacts operations based on PPE burn rate; and
- Consequence of the shortage and duration of its impact.
Key Questions Before Making Requests
Do you employ essential critical infrastructure workers?
If not, your non-essential workers performing operations for which filtering facepiece respirators would ordinarily be required should be following stay-at-home orders, practicing social distancing, making use of telework options, etc. You should suspend non-essential operations, especially those that would otherwise necessitate workers wearing PPE, the need for which cannot be obviated by effective engineering and administrative controls.
Have you implemented all possible PPE use reduction strategies?
If not, consult CDC, OSHA, and other guidance to reduce or eliminate the need for PPE by eliminating hazards for which PPE would otherwise be required, through other exposure-reduction measures, such as engineering and administrative controls and safe work practices, and other solutions or modifications to business practices as described above.
Have you sought regulatory relief or implemented approved alternatives?
If not, contact the regulator requiring PPE use. Consult FDA regarding Emergency Use Authorizations (EUAs) and guidance, and NIOSH and OSHA notices regarding relief and flexibility guidance and enforcement discretion, respectively, to address PPE need.
Is the PPE needed considered “scarce or threatened medical supplies”*?
If not, this need should be addressed through the typical commercial suppliers; FEMA is only involved in managing inventories of PPE that is also used in healthcare settings.
*See “Memorandum on Allocating Certain Scarce or Threatened Health and Medical Resources to Domestic Use.” PPE subject to this policy includes: N95 respirators and a variety of other filtering respirators; air-purifying respirators; surgical masks; and surgical gloves.
Have you properly defined the need?
If not, apply above guidance to accurately describe your PPE need. These details are necessary for government agencies to consider your request.
Submit a request for assistance.
Submit a request for assistance to your local or state emergency management agency. Continue to pursue PPE though the normal market of suppliers, as not all requests for government assistance will be met. All organizations pursuing PPE should consult NIOSH Buyer Beware guidance.
*This Fact Sheet was updated on May 21, 2020