On June 8, Cal/OSHA submitted emergency regulations to the Office of Administrative Law to define “normal consumption.” As currently drafted, the emergency regulation defines “normal consumption” as the average consumption of specified personal protective equipment (PPE) type and size over a two- year period, with a 200% cap. This approach raises significant concerns, as CHA believes that this definition does not reflect statutory intent.
Despite this, the emergency regulation was approved on June 25. After the approval, Cal/OSHA issued FAQs, which provide that enforcement of the “normal consumption” definition for the (PPE) stockpile will not begin until July 26.
Hospitals should use this time to bring their existing PPE stockpiles into compliance with the normal consumption definition. CHA will continue to update members on any updates to COVID-19 standards or guidance, including PPE compliance. Hospitals with questions should reach out to their OSHA counsel.