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CHA has submitted comments to the Office of Administrative Law (OAL) on Cal/OSHA’s June 8 emergency regulations pertaining to the stockpile of personal protective equipment (PPE), which define “normal consumption” as the average consumption of specified PPE type and size over a two-year period, with a 200% cap.
CHA has significant concerns with this approach and does not believe the definition reflects the statutory intent of Assembly Bill 2537 (Chapter 313, Statutes of 2020).
In addition, CHA has concerns with the timing of the regulation, which required hospitals to have formed their stockpile on or before April 1, 2021. This means that hospitals were required to interpret the statute without guidance and, therefore, created stockpiles based on the plain reading of the statute: the PPE consumption in “normal” conditions, or PPE consumption in 2019.