In the Absence of Appropriate Personal Protective Equipment, can the SLP provide Requisite Services?

March 23, 2020

Over the past week, ISHA has received emails from members regarding guidance on how to proceed in the absence of appropriate personal protective equipment.  Sarah Warren, Director, Health Care Policy, Medicare for ASHA provided the following information. 

In the absence of appropriate personal protective equipment (PPE), can the SLP provide requisite services?
ASHA recommends implementation of infection control guidelines from the Centers for Disease Control (CDC) and World Health Organization (WHO) who propose specific recommendations for health care workers. However, ASHA recognizes that many of our members who work in health care settings that are facing acute (global) shortages of PPE. ASHA prioritizes the health and safety of its membersand has strongly encouraged health care organizations withwhom it has engaged in advocacy, to ensure appropriate supply of PPE for SLPs for all aspects of service delivery.  Per Occupational Safety and Health Administration(OSHA), "Employers of healthcare workers are responsible for following applicable OSHA requirements, including OSHA's Bloodborne Pathogens (29 CFR 1910.1030), Personal Protective Equipment (29 CFR 1910.132), and Respiratory Protection (29 CFR 1910.134) standards." See the Standards page on the OSHA website for additional information on OSHA requirements.
Many SLPs are concerned about client abandonment if they refuse to provide services without appropriate PPE. ASHA's Issues and Ethics Statement on Client Abandonment states that some disruptions of clinician-client relationships are involuntary. As such, "clinical relationships may also be interrupted if an organization decides to close a program or when natural disasters occur. It is expected that even in these types of situations, practitioners would hold paramount the welfare of the clients they serve; however, no clinician is ever ethically required to work without pay or to place themselves in physical danger in order to offer client care," (ASHA, 2019).

The following resources provide relevant information specifically related to access and use of PPE during the COVID-19 pandemic:

o U.S. Department of Labor Occupational Safety and Health Administration (OSHA) provides Guidance on Preparing Workplaces for COVID-19, including access to PPE.
o WHO outlines rights and responsibilities of healthcare workers and their employers for occupational safety and health in light of COVID 19 outbreak.
o The CDC offers suggestions for optimizing the supply of PPE, as well as contingency plans for when supplies are limited and/or have completely run out.
o The CDC offers Strategies for Optimizing the Supply of PPE, which include cancelation or delay of non-urgent services. Some states and facilities have chosen to interpret this as inclusive of rehabilitation services.”

**It should be noted that ASHA has given permission for this information to be published on the ISHA website.