NAHC on OSHA Temporary Standards

Thursday, July 1, 2021 at 3:00 pm Eastern

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Clarification on the NAHC OSHA ETS presentation and nebulization
During the NAHC OSHA ETS presentation it was stated the nebulizer treatments are aerosol generating procedures (AGP).

Although a nebulizer treatment is an AGP, OSHA does not include nebulization in the list of AGP for the OSHA ETS because evidence of COVID-19 transmission through nebulizer treatments is inconclusive. Therefore, the requirements within the standards related to AGP do not apply to nebulizer treatments.

NAHC recommends treating nebulization as potential risk procedure for COVID-19 spread and encourages clinicians to use precautions and physical distancing when present during nebulizer treatments.

From the Occupational Exposure to COVID-19; Emergency Temporary Standard, Page 32576 2021-12428.pdf (

“Development of a comprehensive list of AGPs for healthcare settings has not been possible due to limitations in available data on which procedures may generate potentially infectious aerosols and the challenges in determining if reported transmissions during AGPs are due to aerosols or other exposures (CDC, March 4, 2021). Furthermore, there is neither expert consensus, nor sufficient supporting data, to create a definitive and comprehensive list of AGPs for this ETS (CDC, March 4, 2021). For example, based on limited available data, it is uncertain whether aerosols generated from some procedures, such as nebulizer administration and high-flow oxygen delivery, may be infectious. More specifically, aerosols generated by nebulizers are derived from medication in the nebulizer, and it is uncertain whether potential associations between performing this common procedure and increased risk of infection might be due to aerosols generated by the procedure or due to increased contact between those administering the nebulized medication and infected patients (CDC, March 4, 2021)

Therefore, the only medical procedures that are considered AGPs for the purposes of this ETS are: Open suctioning of airways; sputum induction; cardiopulmonary resuscitation; endotracheal intubation and extubation; non-invasive ventilation (e.g., BiPAP, CPAP); bronchoscopy; manual ventilation; medical/surgical/ postmortem procedures using oscillating bone saws; and dental procedures involving ultrasonic scalers, high-speed dental handpieces, air/water syringes, air polishing, and air abrasion.”

I apologize for the confusion.

Mary Carr
V.P. for Regulatory Affairs
National Association for Home Care & Hospice