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CHA News

Hospital PPE Stockpile Deadline Approaching While Ambiguity Remains

For CEOs, government relations executives, supply chain & materials management executives

Labor Code 6403.3 requires general acute care hospitals to maintain a stockpile of specified personal protective equipment, beginning April 1, in the amount equal to three months of normal consumption.

Under the law, covered employers must maintain a stockpile of the following equipment:

  • N95 filtering facepiece respirators 
  • Powered air-purifying respirators with high efficiency particulate air filter 
  • Elastomeric air-purifying respirators and appropriate particulate filters or cartridges 
  • Surgical masks 
  • Isolation gowns 
  • Eye protection 
  • Shoe coverings 

The critical question is how to calculate “three months of normal consumption.”   

While CHA believes that amount should be based on 2019 data, Cal/OSHA does not agree. Rather, Cal/OSHA is undertaking emergency rulemaking to define “normal consumption.” Cal/OSHA held a stakeholder meeting on Feb. 19 to obtain input; CHA provided both verbal and written comments. To date, emergency rulemaking has not yet begun, and it is unclear whether emergency regulations will be final by the April 1 deadline. CHA has updated its FAQs accordingly.