Where Are We on Masks and COVID-19?

As guidelines continue to evolve, you may be wondering if you can ditch your supply of disposable face masks. While they became fixtures of the pandemic, disposable face masks are not government-approved personal protective equipment (PPE). But isn’t the pandemic in our rearview mirror? Aren’t we done with masks already?

If you’re in the transportation industry—airline, rail, transit, or vessel—you already know that face coverings are still with us, because the COVID-19 pandemic has not yet ended. There were 31,845 new cases in the United States on July 14, according to Johns Hopkins University’s coronavirus tracker, with cases rising in California, Texas, Missouri, Arkansas, and Georgia. Across the country, vaccination efforts are progressing at vastly different rates. While nearly 68 percent of the population of the District of Columbia was fully vaccinated by mid-July, less than 34 percent of Alabama’s population was.

Most of the population and most workforces have and will continue to have a mixed vaccination status: some adults are fully vaccinated (two weeks since their single dose of the Johnson & Johnson one-shot vaccine or second dose of the two-dose Moderna and Pzifer vaccines), some may have received their first shot of the Moderna or Pfizer vaccine, and some still are completely unvaccinated.

Aerosol vs. Droplet

Should you hold off on adjusting your workplace policies on masks or face coverings? To understand the usefulness of masks as a precaution in the midst of an ongoing pandemic, it’s important to understand the debate between aerosol and droplet transmission of SARS-CoV-2, the virus that causes COVID-19. At the beginning of the pandemic, public health authorities like the World Health Organization (WHO) and the U.S. Centers for Disease Control and Prevention (CDC) stated that COVID-19 was transmitted through respiratory droplets. Droplet transmission is the rationale behind physical distancing (6 feet or 2 meters) and cleaning and disinfection as infection control measures.

Last summer, infectious disease and public health researchers called on WHO and national public health authorities to recognize the role of airborne transmission through smaller aerosol particles. Since aerosol particles are smaller than respiratory droplets, they can persist longer in an indoor environment and transmit infectious diseases farther than 6 feet.

In a July 12 letter to CDC Director Rochelle P. Walensky, MD, National Nurses United (NNU), a nurses’ union, called for reinstating the federal recommendation for universal masking, which mandated that everyone wear face coverings when in public or in physical proximity to others outside their own household. NNU recommended the reinstatement, irrespective of vaccination status, to help reduce the spread of SARS-CoV-2, especially the Delta variant.

NNU also called for the CDC to update its healthcare infection control recommendations and other COVID-19 guidance to fully recognize aerosol transmission. NNU contends that CDC’s current recommendations are not aligned with the recognition of airborne transmission.

OSHA Employer Guidelines

Following the CDC’s recommendation that those fully vaccinated no longer need to wear masks or maintain physical distancing, the Occupational Safety and Health Administration (OSHA) updated its guidance on COVID-19 for employers on June 10. OSHA’s current stance is that most employers no longer need to take steps like masks and physical distancing to protect their fully vaccinated workers who are not otherwise at risk from COVID-19 exposure. However, OSHA made clear both in its updated guidelines for employers and a later enforcement directive to its area offices that the agency is refocusing agency resources on protecting the health of unvaccinated workers.

While the federal COVID-19 emergency temporary standard (ETS) only applies to healthcare and healthcare support industries, OSHA is looking to all employers to protect their unvaccinated employees in a workforce with mixed vaccination status.

If OSHA compliance safety and health officers (CSHOs) show up at your door, perhaps in response to an employee complaint, they will be looking for compliance with the full set of recommended infection control protections, including masking, physical distancing, cleaning and disinfection, ventilation, and the use of physical barriers to control transmission.

OSHA also recently updated its COVID-19 national emphasis program (NEP), removing a list of secondary targeted industries. However, industries in the NEP’s list of primary targets include correctional facilities, the postal service, discount department stores, full-service and limited-service restaurants, general warehousing and storage, supermarkets and other grocery stores, and temporary employment services.

K-12 School Staff, Teachers, and Students

When CDC recently issued updated guidance for K-12 schools, the takeaway by the media was that fully vaccinated students and teachers need not wear masks in classrooms. However, the guidelines clearly recognize that not everyone is fully vaccinated (children under 12 years old are not even eligible for the COVID-19 vaccines), necessitating the continued use of masking and physical distancing to prevent transmission.

California has gone even further, requiring universal masking in its schools. The California Department of Public Health (CDPH) recently updated its own guidelines for K-12 schools, maintaining a requirement for universal masking of staff, students, and teachers in indoor settings. Masks are the simplest and most effective safety mitigation measure against transmission, according to CDPH. While physical distancing generally reduces droplet transmission, according to state health officials, masks help control both droplet and aerosol transmission. CDPH plans to revisit its mask requirement by November 1.

While the CDC advised that fully vaccinated people can resume normal activities without wearing a mask or physically distancing, the COVID-19 pandemic is still with us, so face coverings and physical distance recommendations remain in place for workforces with mixed vaccination status. And as previously mentioned, masks are also still required throughout the transportation industry, including aircraft, buses, trains, and vessels, as well as airports and transportation terminals.

Nonhealthcare, Nontransportation Industries

In its updated COVID-19 guidance, OSHA also recommended that employers provide unvaccinated and otherwise at-risk workers with face coverings or surgical masks, and that businesses suggest that unvaccinated customers, guests, and visitors wear face coverings. OSHA recommended implementing physical distancing of at least 6 feet for unvaccinated and otherwise at-risk workers in communal work areas and using transparent shields or other solid barriers, such as fire-resistant plastic sheeting or flexible strip curtains, where distancing is impractical.

In addition to requiring the use of face coverings in K-12 schools and childcare facilities, CDPH also requires them in healthcare and long-term care facilities, correctional facilities and detention centers, homeless shelters, emergency shelters, and cooling centers. California businesses and venues are permitted to require all of their patrons to wear masks.

In Los Angeles County, unvaccinated people must wear a mask in entertainment venues, restaurants, and retail stores, as well as at events and meetings. The county also strongly encourages the vaccinated to wear masks in indoor settings.

Current, Future Nonregulatory Masks

The National Institute for Occupational Safety and Health (NIOSH) recently issued criteria for nonregulatory masks to help protect workers from the SARS-CoV-2 virus, the cause of COVID-19. The NIOSH criteria incorporate the American Society for Testing and Materials (ASTM) Specification for Barrier Face Coverings (F3502-21), establishing minimum care, design, labeling, and performance guidelines for masks.

The masks described in NIOSH’s new Workplace Performance Mask and Workplace Performance Plus Mask criteria are not meant to be used as substitutes for respiratory protection. The masks certified under ASTM’s F3502 specification also are not intended for use in medical procedures for source control.

Manufacturers who want to market masks with ASTM’s F3502 label must supply a certified testing laboratory with 10 specimens. While the ASTM performance criteria address filtration and breathability, the NIOSH criteria address leakage and labeling with additional performance criteria that includes testing for leakage.

During the pandemic, OSHA made it clear that the agency did not consider face coverings to be PPE. In its latest COVID-19 enforcement directive, the agency also rescinded inspector discretion in the reuse of disinfected filtering facepiece respirators (FFRs) or the use of foreign-made FFRs lacking NIOSH approval.

Last year, four states–California, Michigan, Oregon, and Virginia–established their own COVID-19 ETS that included requirements to use and/or provide face coverings for employees. California renewed its ETS with revisions last month; Michigan recently eased some of its requirements; and Oregon and Virginia established permanent COVID-19 standards.

Oregon’s permanent COVID-19 standard became effective May 4 and remains in force until repealed. Oregon OSHA on June 30 removed the facial covering and physical distancing requirements of its COVID-19 rule for all workplaces because Oregon had reached its goal of vaccinating 70 percent of all adults against COVID-19, while many states are nowhere near that level.

Virginia’s permanent COVID-19 standard became effective January 27 and requires employers in the state to provide face coverings for their employees and require their use. Under the state rule, face coverings must be worn over the wearer’s nose and mouth and extend under the chin, and must be worn when employees solely exposed to lower-risk hazards or job tasks have brief contact with others inside of 6 feet. Face shields may not be used in place of face coverings under the Virginia rule.

Newer, Better Nonregulatory Masks on the Way

New and improved nonregulatory masks may be on their way. Design teams have been competing in public and private mask innovation challenges. NIOSH and the Department of Health and Human Services’ Biomedical Advanced Research and Development Authority (BARDA) recently announced 10 winners in Phase 1 of their Mask Innovation Challenge aimed at improving comfort and utility, as well as protective capabilities of products worn when physical distancing is not possible. Phase 1 winners included teams at Amazon Services, LLC; Georgetown University in Washington, D.C.; and Levi Strauss & Co. Details on Phase 2 of the challenge will be forthcoming, according to the agencies.

Luminosity Lab at Arizona State University in Tempe, Arizona, was the winner of XPRIZE’s Next-Gen Mask Challenge with its FloeMask design. A Nigerian team and a team of engineering students at Johns Hopkins University in Baltimore were the runners-up in XPRIZE’s design competition.

So masks are still required in some places and industries, but better masks are coming. It’s important to remember that while the pandemic continues, public health recommendations not subject to public comment can change, agencies don’t release advance drafts, and enforcement agencies like OSHA continually update and refine their guidelines and enforcement policies.

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