Letter to John Howard, Director of the National Institute for Occupational Safety and Health and Maryann D'Alessandro, Director of the National Personal Protective Technology - Colorado Delegation Urges Expedited National Review of PPE Developed at Colorado Universities

Letter

Dear Directors Howard and D'Alessandro,

In light of the Coronavirus Disease 2019 (COVID-19) pandemic, we urge your strong and expedited consideration of the development and assessment of Personal Protective Equipment ("PPE") by universities in Colorado. We also ask that you release clear guidance on how universities can obtain expedited approval to certify release of tested PPE for distribution as compliant with National Personal Protective Technology Laboratory ("NPPTL") and National Institute for Occupational Safety and Health ("NIOSH") standards, and that moving forward you continually, fairly assess innovation of PPE devices completed at these universities.

As you know, the need to rapidly obtain and distribute PPE in response to the COVID-19 epidemic is urgent. In Colorado alone, countless hospitals, clinics, and other health care facilities have seen their stock of PPE nearly or totally depleted and are therefore having to resort to sterilizing and recycling products meant for one-time use. The resources provided to Colorado from the Strategic National Supply fulfilled our health care industry's needs throughout our state for only one day. As the outbreak continues to grow, so too will the need for these supplies.

In response to the COVID-19 pandemic, Colorado State University, University of Colorado, and other research universities in our state and across our country are heeding the call to help with assessment of PPE when products are purchased outside of the continental United States, and for the innovative production of PPE components. Colorado State University, for example, has expanded its SARS-CoV-2 testing capability to include pressure and particle flow testing of N-95 masks with NIOSH sponsored investigators and faculty engaged. Meanwhile, the University of Colorado Boulder's Engineers are using 3D printers in two campus labs to make the bands used for protective face shields as part of the University of Colorado's make4covid initiative across each of their campuses.

As the unprecedented, emergent nature of the COVID-19 outbreak grows in our state and throughout the United States, we implore you to demonstrate haste and transparency in your approval process for minimum performance requirements defined in Title 42, Part 84 of the Code of Federal Regulations. Specifically, we ask that NIOSH grant PPE testing labs authority to certify release of tested masks for distribution and for strong consideration of future PPE developments spearheaded by these universities. We ask that NIOSH give strong consideration to authorizing these labs, which already implement NIOSH standards and guidelines, to extend their current assessments to physical performance, enabling certification of PPE products, especially N95 masks. Our understanding is that the laboratories agree to provide to NIOSH all of the data used in the assessments needed to rapidly deploy these lifesaving products.

For the safety of our frontline health care workers and the overall health of our communities, we implore you to take and inform us of these steps immediately.

Thank you for consideration.