Today marks the day that hospitals are required to have a personal protective equipment (PPE) stockpile per Labor Code 6403.3. The law is clear that the stockpile must consist of seven identified items of PPE in amounts equal to three months of normal consumption. Among other questions, the definition of normal consumption remains unresolved. While CHA continues to advocate that “normal consumption” is defined in reference to 2019 data, Cal/OSHA has not committed to that approach.
Cal/OSHA is working on FAQs, which should be available shortly. It is CHA’s understanding that Cal/OSHA intends to pursue emergency rule-making to define “normal consumption.” Once initiated, the rule-making process should be complete in approximately 10 days. It is also CHA’s understanding that Cal/OSHA will provide a grace period for hospitals to procure and store any additional equipment necessary to achieve compliance with the emergency regulations.
CHA has also developed frequently asked questions to assist hospitals in the absence of any Cal/OSHA guidance and will provide further information as it becomes available.