Support a National Standard for N95s (and other respirators) in Healthcare

A blue, black and yellow graphic features a hand-drawn illustration of a headstrap N95 mask entwined with a stethoscope, with tubing coiled in the shape of a heart. Text reads, Support a National Standard for N95s (asterisk - and other respirators!) in Healthcare. Have your say by August 19, 2025. Summary and template answersa at www.DoNoHarmBC.ca In the corner is the DoNoHarm BC logo and a QR code leading to their website

Read below to find out more, including a step-by-step on how to take part, and template answers to make it easier!

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French version here / Version française ici.
Thank you to the Canadian Covid Society for the French translation.

What’s a CSA standard, and why does it matter?

CSA is an abbreviation of the “Canadian Standards Association”, referred to as CSA Group. They are a widely-known non-profit organization that helps make products and processes more safe and effective. A major way they do this is by creating standards: sets of best-practice rules, guidelines, and definitions that many different organizations can follow to get a consistent outcome, or to double-check each others’ work.

Many standards are voluntary, meaning that industries can choose whether to use them widely. However, standards can become legally required when laws say that people need to follow them. CSA policies affect almost every workplace in Canada: for example, most provinces and territories require workplaces to have a CSA-compliant first aid kit, to use CSA-approved eye protection, and so on.

What is CSA standard Z94.4?

Z94.4 is a CSA standard about using respirators (like N95 masks) in the workplace. It includes requirements that must be followed in order to meet the standard. It also includes info, explanations, and recommendations that aren’t required. 

Because Z94.4 is about workplace health and safety, it applies to organizations and workers, but not to members of the general public. However, it can still help the public by protecting them from contagious workers – and by showing that experts say respirators are needed for airborne illnesses.

The first edition of Z94.4 came out in 1982, and it has been updated several times since then. There is a new edition coming out in 2025, which is now open for public review.

Both BC and Canadian law mention Z94.4. Right now BC workplace regulations say that if workers are exposed to airborne contaminants, workplaces need to use respirators in accordance with Z94.4, but only an outdated version from 1993. (Getting those regulations updated is a task for another day!)

About this advocacy opportunity

Right now, CSA is looking for feedback on their newest (2025) edition of Z94.4 before it’s finalized. Any member of the public can give feedback.

The draft of this new edition includes some important changes, like more recognition of how airborne transmission can cause infections, and supporting the wider use of elastomeric (reusable) respirators.

CSA have also added a chapter about healthcare settings, which says that:

  • Respirators need to be worn by healthcare workers at all times in healthcare facilities and where healthcare services are being performed, except in “exempted zones” (clause 9.6.2)
  • surgical masks aren’t good enough for workers to use as respiratory protection, though they may be given to patients if they can’t wear a respirator (9.6.3.11)
  • Respirators are to be supplied free of charge in healthcare facilities to all occupants, including at entrances and in nursing stations, waiting rooms, procedure rooms, and patient rooms (9.6.3.5)

This is a vital change in guidance, from a very respected organization.

It’s crucial that people comment, in order to:

  • Support and reinforce key improvements (particularly in case of pushback)
  • Give feedback on any gaps or issues, so the finalized standard can be stronger. 

Once the public comment period closes, CSA’s volunteer working groups will read all the feedback and make their final changes. We know that they pay attention to feedback, because past comments helped get important improvements into this draft. 

After CSA makes the final changes, the new edition of CSA Z94.4 will be released – ready for us to use, cite, and push to get implemented in as many places as possible! The standard will also be reviewed in the future for further improvements, within 5 years.

How to give feedback:

Note: we have sample feedback answers below to make things easier. 

  1. Log in to https://publicreview.csa.ca/Home/Details/5674 or create an account.
  2. Go to the CSA Z94.4 Public Review Draft (titled “Selection, use and care of respirators”). 
  3. Navigate to each section you want to comment on, using the table of contents on the left.
  4. When you reach the section you want to comment on, hit the fuchsia button “Comments”. 
  5. Add your feedback, and include a specific change you want them to make. Each text box has a limit of 2000 characters.
    • Note: at the bottom of the comment box you can label your comment “general”, “editorial”, or “technical” – find definitions here. Most of our example feedback is “technical”.
  6. Press “submit comment” when you’re done. (If you want to save the comment and finish it later, hit “save comment” instead – just make sure you remember to submit it later!)

Please note:

  • other members of the public can’t see the comments that you leave. 
  • You can leave more than one comment on each section.

For more help submitting comments (including screenshots!), read this CSA help page.

Overview of Z94.4, 2025 edition (public review draft)

If you want to have a better sense of the whole standard, check out our speedy section guide below. Sample responses are included after that, for some of the key sections.

Note: in the standard, if something is required, the wording will say you “shall” do something. If it’s just a recommendation but not mandatory, it’ll say you “should” do it. If it’s just an option to consider, it’ll say you “may” do it.

We have highlighted some of the most relevant sections from our perspective. Suggestions for comment are provided below for these sections.

Main sections:

Sections 1 and 2 explain what the standard applies to, and what it doesn’t, as well as some of the other standards and publications they reference.

Section 3:  Definitions of specific words as used in the standard.

Section 4: explains about different types of respiratory protection, from disposable N95 type masks, up to the equipment and air tanks that firefighters might wear. All of these things count as respirators!

Sections 5 and 6: explains that employers need to have a “respiratory protection program”, with people who are responsible for doing things like checking for airborne hazards, and making sure workers wear appropriate respirators that fit them well. 

Section 7: explains how to do “hazard identification” – where someone figures out if there are any airborne hazards that could require respiratory protection. Section 7.3 is specifically about “bioaerosols” – airborne hazards from living organisms, such as bacteria, viruses, or fungal spores.

Section 8: explains how to choose the right respirators in workplaces other than healthcare settings, and what factors to consider.

Section 9: explains how to choose the right respirators in healthcare workplaces (which includes any location where healthcare is being performed: hospitals, clinics, care homes, ambulances, or a patient’s home).

Section 10: explains how to train people to use respirators properly.

Section 11: explains how to do respirator “fit testing” (a test that’s required for workers, to make sure the model of respirator they’re wearing doesn’t leak).

Sections 12 and 13: explains more details about using particular types of respirators, and how to clean and maintain reusable respirators.

Section 14: explains how to screen workers to make sure they don’t have health issues that could interfere with using a respirator safely.

Sections 15 and 16: explains how to make sure a workplace respiratory protection program is effective, and how to keep records about it.

Annexes:

Note that Annexes are either “informative” (meaning they just include info or suggestions) or “normative” (meaning they contain requirements that must be followed in order to meet the standard). 

We’ve highlighted some of the annexes that we think may be most relevant to DoNoHarm BC’s own priorities.

Annex A. (informative): Wearer seal checks

Annex B. (normative): Qualitative respirator fit tests (QLFT) 

Annex C. (normative): Quantitative respirator fit tests (QNFT)

Annex D. (informative): Use of SCBA in low-temperature environments

Annex E. (informative): Health surveillance

Annex F. (informative): Procedures for cleaning and sanitizing re-usable respirators in the absence of manufacturers’ instructions for use

Annex G. (informative): Respirator classification, characteristics, and limitations

Annex H. (informative): Reduced oxygen concentration

Annex I. (informative): Buddy breathing

Annex J. (informative): Checklist of competency for respirator fit testers

Annex K. (informative): Scenarios using bioaerosol respirator selection procedures

Annex L. (informative): Classification of micro-organisms by risk group

Annex M.(informative): Bioaerosol concentrations measured in workplaces

Annex N. (informative): Persistence of bacteria, fungi, viruses, and other pathogens

Annex O. (informative): Illustrations of acceptable and unacceptable facial hair for tight-fitting respirators with a face seal

Annex P. (informative): Employer strategies to identify and address barriers to respiratory protection accessibility

Annex Q. (informative): Example respirator fit testing records form (QLFT and QNFT)

Example feedback answers

While logged in, navigate to the relevant sections of the standard via the table of contents, and then press the “Comments” button to leave your feedback. You can leave more than one comment on each section.

If you have capacity, we encourage you to customize the example feedback, and of course, to include your own thoughts and suggestions! There is a 2000-character limit for each comment box.

Comment on this clause/subclause: 

Bioaerosol

The definition of bioaerosols could lead to misunderstandings: specifically, where it mentions that liquid aerosols can be “generated, for example, by coughing, sneezing, or a medical procedure such as bronchoscopy”. 

Many people erroneously believe that ONLY coughs, sneezes, or so-called aerosol-generating medical procedures cause infectious airborne particles – i.e. that bioaerosol generation occurs only when provoked. Due to this misunderstanding, some healthcare settings refuse to use respirators unless an AGMP is being performed. This is despite the fact that breathing, speaking, shouting, and singing all generate similar or higher levels of aerosols to many AGMPs  – and breathing and speaking occur over much longer periods of time than single medical procedures. 

Further details:

Greenhalgh T, MacIntyre CR, Baker MG, Bhattacharjee S, Chughtai AA, Fisman D, Kunasekaran M, Kvalsvig A, Lupton D, Oliver M, Tawfiq E, Ungrin M, Vipond J. 2024. Masks and respirators for prevention of respiratory infections: a state of the science review. Clin Microbiol Rev 37:e00124-23.

Stadnytskyi V, Anfinrud P, Bax A. 2021. Breathing, speaking, coughing or sneezing: what drives transmission of SARS-CoV-2? J Intern Med 290:1010–1027.

Wilson NM, Marks GB, Eckhardt A, Clarke AM, Young FP, Garden FL, Stewart W, Cook TM, Tovey ER. 2021. The effect of respiratory activity, non-invasive respiratory support and facemasks on aerosol generation and its relevance to COVID-19. Anaesthesia 76:1465–1474.

Proposed change: 

Expand the description of liquid aerosols to include “breathing, speaking or singing, coughing or sneezing, or certain medical procedures as per clause 7.3.7.2”. 

Comment type: 

Technical

Comment on this clause/subclause: 

Additional Definitions

A few terms are not defined here, which may have implications for the practical application of guidance. 

In particular, without a specific definition for the term “pandemic” there could be inconsistent usage of W1-2 and P1-2 designations. Many people colloquially use the term “pandemic” to mean different things – for example geographically widespread, poorly-controlled levels of transmission; use (or lack) of safety requirements or behaviours, regardless of hazard levels; localized emergency declarations; WHO Public Health Emergency of International Concern (PHEIC) declarations.

Note that a PHEIC is actually defined separately from a pandemic: in fact, when the WHO declared an end to the PHEIC for COVID, their leadership emphasized that COVID continues to be a “global health threat” (https://www.who.int/news-room/speeches/item/who-director-general-s-opening-remarks-at-the-media-briefing—5-may-2023) and that we are “still in a pandemic” (https://www.scientificamerican.com/article/rampant-covid-poses-new-challenges-in-the-fifth-year-of-the-pandemic/). 

Proposed change: 

Add definitions for the terms “Precautionary Principle”, “Pandemic”, and “Hierarchy of Controls”; consider adding “Source-Pathway-Receiver Model”. 

The definition of pandemic should also include examples of what the standard considers “equivalent circumstances” or “situations where risk of infection transmission in the community is recognised as heightened”. For example: “This includes when the WHO has declared a Public Health Emergency of International Concern; when there is a state of emergency at regional or national levels due to transmissible illness; when wastewater monitoring systems, infectious disease modelling, or other hazard indexes identify community spread of illnesses with airborne transmission mechanisms; when infection risk management mode is in effect (ASHRAE 241-2023); and/or or when the qualified person identifies community risks, such as natural disasters, that they deem equivalent to the above.”

Comment type: 

Technical

7.2.1 Respirable Hazards

Comment on this clause/subclause: 

Some contaminants are present only intermittently – for example, communicable diseases may depend on which people or animals are present (or have previously been present, since aerosols can linger even after the source has exited the space). Likewise, air quality hazards for outdoor work may fluctuate.

Language must clearly reflect the need to identify potential as well as actual contaminants (as later referenced in 7.3.5.1) , in ways that consider broader community context.

Proposed change: 

Amend item a) to read, “identify what contaminants are present, or have the potential to be present, in the workplace and the general hazard environment”. 

Add a line stating that where a hazard has been deemed present in the community by a public health authority or similar body, that hazard shall be deemed present in the workplace. 

Comment type: 

Technical

7.2.2 Identification of contaminants and the hazard environment  

Comment on this clause/subclause:

Identifying bioaerosol hazards in this stage is crucial in order for users to advance to section 7.3 (and from there, into the respirator selection process). This is made clear in clause 7.2.10, which states that “If, during the identification process in Clause 7.2.2, a bioaerosol has been identified as present, continue to Clause 7.3.”

With that in mind – wording in section 7.2.2 should specifically consider factors associated with potential or actual bioaerosol exposures, to ensure they are not missed.

Proposed change: 

Amend the first sentence to state, “to assist in identifying potential or actual contaminants”. 

Add wording in point a) to mention the release of air contaminants through “routine or non-routine procedures, presence or activities of humans or animals,” etc. in order to reference common communicable disease vectors.

Add another point mentioning that the assessor should consider hazards deemed present more broadly in the community, for example a public health authority.

Comment type: 

Technical

7.3.3.3 Non-healthcare workplaces

Comment on this clause/subclause: 

Clarity is needed about what constitutes “pandemic circumstances” or “situations where risk of infection transmission in the community is recognized as heightened”.

Many people colloquially use the term “pandemic” for different things: geographically widespread, poorly-controlled levels of transmission; use (or lack) of safety requirements or behaviours, regardless of hazard levels; localized emergency declarations; WHO Public Health Emergency of International Concern (PHEIC) declarations.

Additionally, “heightened” transmission could have an ambiguous meaning in circumstances where baseline levels of transmission are high over long periods of time. Does “heightened” mean that transmission must be higher than an already-high baseline? Or does it mean “high” transmission, even if that level is ongoing?

Proposed change: 

Add a note specifying what constitutes pandemic circumstances or situations where risk of infection transmission is heightened. For example: “This includes when the WHO has declared a Public Health Emergency of International Concern; when there is a state of emergency at regional or national levels due to transmissible illness; when wastewater monitoring systems, infectious disease modelling, or other hazard indexes identify community spread of illnesses with airborne transmission mechanisms; when infection risk management mode is in effect (ASHRAE 241-2023); and/or or when the qualified person identifies community risks, such as natural disasters, that they deem equivalent to the above.”

Last sentence of clause: add “or equivalent” after the words “during pandemic circumstances”.

Comment type: 

Technical

Same clause as above (7.3.3.3)

Comment on this clause/subclause: 

The word “and” at the end of point b) suggests that conditions a, b, and c must ALL be met in order for level W2 to apply.

Also – heightened workplace transmission risks may occur in enclosed, insufficiently-ventilated spaces even when personnel are not located within 2 meters of each other, particularly with high-generation activities.

Proposed change: 

To the sentence “Level W2 applies where, during pandemic circumstances”, add the words “any one or more of the following conditions are met”. 

Change the “and” at the end of point b) to “and/or”. 

To point c), consider adding the following wording at the end: “or where high-generation rate activities (G3 as per clause 8.3.6.2) occur in enclosed spaces with large groups of people.”

Comment type: 

Technical

7.3.4 Risk assessment concept: Source-Pathway-Receiver

Comment on this clause/subclause: 

In addition to respirators being used for “personal” protection (PPE), they are often used for source control for communicable disease. This adds complexity to the statement, “PPE usage is indicated only if the source and pathway controls are not adequate”: that statement could be interpreted as asserting that respirators should not be used as source control (despite discussion of that option in clause 7.3.7.5 and section 9, and data indicating two-way masking is more effective in reducing transmission: https://www.acgih.org/covid-19-fact-sheet-worker-resp/).

Proposed change: 

Either add a clarifying note, or revise the sentence “PPE usage is indicated only if the source and pathway controls are not adequate…” to read, “The usage of personal protective equipment (PPE) is indicated only if the source and pathway controls are not adequate to prevent inhalation of a hazardous bioaerosol. It should be noted however that respirators are often used not only for personal protection, but as a form of source control – see clause 7.3.7.5 for more.”

Comment type: 

Technical

Table 1. Assignment of Micro-organism Hazard Levels for Risk Analysis and Respirator Selection  

Comment on this clause/subclause: 

For COVID-19, many people have colloquially used “serious/severe illness” to solely refer to hospitalization during the acute infectious period, without regard to serious long-term effects such as Long COVID, organ damage, or elevated risks of stroke, diabetes, dementia, autoimmune diseases etc.

Proposed change: 

For all hazard levels, add the phrase “including long-term health effects” after “adverse health effects”.

Comment type: 

Technical

7.3.7.2 Human and animal sources  

Comment on this clause/subclause: 

It may be helpful to explicitly state that aerosolized contaminants can linger even when the initial human or animal source is no longer present.

Proposed change: 

Revise the beginning of the sixth paragraph (“It is notable that…”) to read, “It should be noted that aerosols may linger in enclosed spaces even after the human or animal source has exited the space. Furthermore, dispersion of initially human- or animal-originated micro-organisms…”

Comment type: 

Technical

7.3.7.4 Source factors affecting acquisition of adverse health effects  

Comment on this clause/subclause: 

It may be useful to elaborate on what it means that a source of bioaerosols may “not be in the immediate vicinity of the receiver”. 

Proposed change: 

Amend last sentence to, “It should be considered that sources may not be in the immediate vicinity of the receiver, depending on workspace layout, air flow patterns (including between areas or floors of a building), and the fact that aerosols may linger even after infected humans or animals have exited the space.”

Comment type: 

Technical

7.3.7.5 Controls at source 

Comment on this clause/subclause: 

It’s useful to clarify the limitations of relying solely on masks for source control, in the absence of standards certifying outward leakage. However, some of this wording could be cherry-picked to explicitly argue against “two-way masking” or universal usage of respirators, though that’s promoted elsewhere in the standard (section 9).

Research supports the benefit of using respirators as source control; in one study, risk of infection was reduced approx. 74-fold when both infected and susceptible parties wore well-fitting FFP respirators, compared to surgical masks. Balance is needed in this wording, to both address the limitations and unknowns around relying on masks as source control, while not appearing to discourage the use of an added layer of protection.

References: 

Greenhalgh T, MacIntyre CR, Baker MG, Bhattacharjee S, Chughtai AA, Fisman D, Kunasekaran M, Kvalsvig A, Lupton D, Oliver M, Tawfiq E, Ungrin M, Vipond J. 2024.Masks and respirators for prevention of respiratory infections: a state of the science review. Clin Microbiol Rev 37:e00124-23.https://doi.org/10.1128/cmr.00124-23

Nie Z, Chen Y, Deng M. 2022. Quantitative evaluation of precautions against the COVID-19 indoor transmission through human coughing. Sci Rep 12:22573

Bagheri G, Thiede B, Hejazi B, Schlenczek O, Bodenschatz E. 2021. An upper bound on one-to-one exposure to infectious human respiratory particles. Proc Natl Acad Sci U S A 118:e2110117118

Proposed change: 

After the phrase “…but have limited effectiveness in preventing aerosol dispersion”, add:

“Notwithstanding the above, evidence supports a net benefit (i.e. reduced transmission) when both infected and susceptible parties are wearing masks and particularly respirators, known as “two-way masking”. Note that both the Source-Pathway-Receiver model and Hierarchy of Controls prioritize use of source controls where possible. In all cases, the precautionary principle should be applied.”

Comment type: 

Technical

Same clause as above (7.3.7.5)

Comment on this clause/subclause: 

The reference included (https://blogs.cdc.gov/niosh-science-blog/2020/09/08/source-control/) contains outdated information – specifically, an explicit recommendation that the general public not wear respirators to protect themselves from COVID-19. 

Proposed change: 

Consider finding an alternative reference. 

Comment type: 

Technical

7.3.10 Risk of exposure, leading to selection  

Comment on this clause/subclause: 

To qualify as Level A (no respiratory protection needed) in the presence of a bioaerosol source, the clause states that there must be both limited generation, AND source/pathway controls must be strongly effective in limiting receiver exposure “unless there is close range contact”. But what if there IS close-range contact – potentially a significant amount? This leaves a potential loophole that could interact in troubling ways with clause 9.4.1 (healthcare settings).

The standard itself notes that “engineering controls are generally insufficient to protect users in close proximity to sources” (7.3.8.5), while adding that “Air mixing and bioaerosol concentration equilibration in indoor workspaces means that the significance of proximity reduces where exposure is continuous in indoor settings” (8.3.6.3). 

Proposed change: 

After “unless there is close range contact”, state, “If there is significant close range contact, or if there is contact with patients in healthcare settings, level B shall be chosen.”

Comment type: 

Technical

8.3.4.2 Pandemic or equivalent circumstances  

Comment on this clause/subclause: 

Would love to see P2 (pandemic or equivalent circumstances) even more clearly defined, since many people use the term pandemic colloquially to mean different things, and emergency declarations (or lack thereof) are not the same thing as a pandemic itself. 

It’s good that ASHRAE 241’s infection risk management mode is mentioned, but 241 is also not very specific about the criteria of usage, adding to further ambiguity.

Proposed change:

For level P2, adjust or expand wording, for example as follows: “Where a pandemic or equivalent circumstances are occurring, including but not limited to: 

– when the WHO has declared a Public Health Emergency of International Concern
– when there is a state of emergency at regional or national levels due to a communicable disease involving airborne transmission
– when wastewater monitoring systems, infectious disease modelling, other hazard indexes or reporting, or public health alerts identify community spread of a disease involving airborne transmission
– when infection risk management mode is in effect (see ASHRAE 241-2023)
– when the qualified person identifies community risks, such as a natural disaster, that they deem equivalent to the above.”

Comment type: 

Technical

9.3 Risk analysis for healthcare facilities 

Comment on this clause/subclause: 

I strongly support the addition of section 9, and the provision requiring respirators by default in all healthcare facilities and wherever healthcare is being delivered. 

That being said – I’m deeply concerned about the broad language around “exempted zones”, and how the methodology used to designate exemptions appears to be entirely discretionary. 

Currently, many medical facilities do not use respirators frequently or at all, and may put patients with airborne illnesses (such as COVID) in group settings alongside uninfected people, separated only by gappy curtains. As of July 2025, the Canadian Nosocomial Infection Surveillance Program (CNISP) finds that around 1 in 3 Canadians hospitalized for COVID, acquired the infection in a healthcare facility.

In this context, it’s critical to set clear minimums to designate exemptions, to ensure safety for both workers and the general population.

I am also concerned by the implication in note 2.f that sufficient engineered AIRBORNE protections could include “barriers to prevent exposure to exhaled jets produced by coughing or sneezing”, when the standard notes elsewhere that “solid barriers with gaps around them… have limited effectiveness in preventing aerosol dispersion” (7.3.7.5). 

Proposed change: 

Implement clear, specific, required minimums for designating exempted zones: for example, documented ongoing compliance with CSA Z8000, CSA Z317.2 and ASHRAE 241, including certification by a professional HVAC engineer.

Add explicit wording stating that designated exempted zones shall not include patient care areas, including areas where patients must wait. This would be in keeping with existing text in 9.6.1, which states that “Patient care requires close contact with both patients and the patient environment that exposes HCWs to bioaerosol exposure risk that cannot be overcome with engineering measures such as ventilation and filtration.”

Add wording to note 2, clarifying that the presence of an engineered airborne protection measure (such as barriers) does not, by default, create sufficient grounds to designate an exempted zone. Reiterate the warning that many engineered airborne protections provide insufficient mitigation upon close contact.

Comment type: 

Technical

11.1.2 Tight-fitting respirator fit  

Comment on this clause/subclause: 

The phrase “No person shall use or be assigned to use a tight-fitting respirator until a satisfactory fit has been verified by a qualitative or quantitative fit test” could be taken out of context to argue AGAINST providing respirators to patients, visitors, or other members of the public. This has already occurred in BC healthcare facilities, where a human rights class complaint is underway due to policies banning patients and visitors from wearing N95s (https://www.cbc.ca/news/canada/british-columbia/n95-use-patients-human-rights-complaint-1.6329330), and many patients have been forced to remove respirators in favour of surgical masks.

Proposed change: 

Add a note specifying that this does not include patients, visitors, or members of the public, for whom fit-testing can be beneficial but is not required, keeping in mind that peer-reviewed research demonstrates even non-fitted respirators are more effective than surgical masks. 

References: 

G. Bagheri, B. Thiede, B. Hejazi, O. Schlenczek, & E. Bodenschatz, An upper bound on one-to-one exposure to infectious human respiratory particles, Proc. Natl. Acad. Sci. U.S.A. 118 (49) e2110117118, https://doi.org/10.1073/pnas.2110117118 (2021).

Greenhalgh T, MacIntyre CR, Baker MG, Bhattacharjee S, Chughtai AA, Fisman D, Kunasekaran M, Kvalsvig A, Lupton D, Oliver M, Tawfiq E, Ungrin M, Vipond J. Masks and respirators for prevention of respiratory infections: a state of the science review. Clin Microbiol Rev. 2024 Jun 13;37(2):e0012423. doi: 10.1128/cmr.00124-23. Epub 2024 May 22. PMID: 38775460; PMCID: PMC11326136.

Comment type: 

Technical

Comment on this clause/subclause: 

More consistency is  needed around how the P1 – P2 (pandemic-related) designations are applied. For example: scenario K.3 is designated P2 (pandemic status) due to the pandemic potential of H5N1, but scenario K.8 is designated P1 (no pandemic-or-equivalent circumstances) even though the identified hazard in that scenario is H5N1.

Also, while I appreciate the specific references to Long Covid in K.10, that scenario is ranked P1 despite the fact that COVID-19 is still a pandemic as per WHO leadership (despite no longer having a public health emergency declaration), and on an international scale there are other illnesses with broad community spread, including measles, and an active Public Health Emergency of International Concern for mpox.

In K.10, the phrase “this consideration is for circumstances outside a pandemic peak” may have been intended to clarify the P1 designation, but could further introduce confusion, by implying that P2 designations only apply to the very “peak” of a pandemic, rather than the current definition of P2 as per 8.3.4.2, which specifically mentions equivalent circumstances such as “community spread of a disease involving significant levels of airborne transmission”.

Proposed change: 

Switch K.8 and K.10 to a P2 designation. If there is a desire to demonstrate a P1 designation for K.10, further clarify the wording to state that this is a hypothetical scenario intended to demonstrate conditions outside of a pandemic or equivalent circumstances.

Comment type: 

Technical

Annex K. (informative)  

Comment on this clause/subclause: 

It would be beneficial to add an example in a school setting, particularly as educational settings are often very crowded, with outdated infrastructure including HVAC systems – and many conversations about preventing illness in schools focus on the safety of children, leaving out the workers entirely. 

Note that a study of over 160,000 US households found that over 70% of household COVID transmission originated from a child (doi:10.1001/jamanetworkopen.2023.16190), suggesting schools are very high-risk for transmission of airborne illnesses. 

Proposed change: 

Add an example scenario in a K-12 educational setting.

Comment type: 

Technical

P.1 Introduction

Comment on this clause/subclause

Strongly support the final sentence that “it is important that any accommodation to be undertaken do not pose undue risks to the health of the respirator wearer or others under the responsibility of the employer”. However, there is a missed opportunity to further note that for members of many marginalized and vulnerable groups in particular, the use of respiratory protection and ensuring a sufficiently safe environment are themselves key to accessibility – and that moreover, workers may incur a duty to accommodate patients or members of the public by wearing respirators. 

For more on this, please review the following statements from BC’s Human Rights Commissioner: 

Proposed change: 

Add an additional sentence noting that ensuring sufficient safety is itself key to many equity and accessibility objectives, and to respecting the rights of those with protected characteristics including but not limited to disability or health status, who are often more vulnerable to airborne hazards, including those transmitted by colleagues. 

Add an additional sentence noting that workers may incur a duty to accommodate patients or members of the public by wearing respirators.

Comment type: 

Technical

Annex P (informative), P.4 Employer considerations for accommodations

Comment on this clause/subclause: 

Regarding point g (“Is the need for accommodation based on an employment goal for inclusivity by allowing personal choice or expression, as opposed to a religious or medical concern?”) – language should make it clear that “personal choice or expression” is not in itself a protected characteristic. This may not be clear in the current language, given that “personal choice” is framed as giving rise to a “need for accommodation”, and being a form of “inclusivity”. We need to be careful that language does not suggest personal preferences incur the same legal or moral obligation as accommodating disability for example (or of upholding statutory obligations to provide a safe working environment).

Proposed change: 

Re-word point g, for example: “Is there a legal duty to accommodate on the basis of a protected characteristic, or is the desire for accommodation on the basis of personal choice or expression?”

Comment type: 

Technical