Comment from Hoag Memorial Hospital Presbyterian, Bryant, MPH, CHFM, HEM, Roxanna

This regulation would pose a huge challenge for hospitals and healthcare organizations to implement and maintain. 1) This is not acceptable for healthcare organziations that are latex-free because of the rubber face masks. Many hospitals are now latex-free for patient and employee safety. 2) This would be cost prohibitive for rmany healthcare organizations to purchase the quantities needed. 3) The maintenance of this equipment would pose another challenge. In most cases, the equipment would not be able to be properly maintained due to limited staffing. It could potentially put healthcare workers at greater risk if they think they are being protected by a piece of equipment when it is damaged or not maintained properly. 4) Storage for this equipment would be a challenge and a limiting factor for some healthcare organizations. There is no room for this equipment in the quantities that are being proposed. Inproper storage would result and would damage them and render them useless in no time at all. 5) Shelf life for this equipment is probably very limited, since it has rubber pieces. This would require inventorying, inspecting, maintaining and turning over expiring equipment. 6) This would require additional fit-testing for healthcare workers. The costs and time it takes for existing annual TB fit testing is enormous. This would double the expenses and time and would be 2 more prohibitive factors. I appreciate your time in reviewing the outlined comments and concerns.