With the arrival of warmer weather, there is a concern that the use of a fan or a similar personal comfort device may impact ventilation systems that are optimized to prevent the spread of the virus that causes COVID-19. There are a few considerations that must take place before using fans in rooms of residents that are suspected or confirmed of having COVID-19.

Heat stress makes people more vulnerable (for example, by dehydration), which could make them more susceptible to infection. The use of a fan or other comfort device for cooling is acceptable on a short-term basis, however, their use should cease if the resident has a suspected or confirmed case of COVID-19. A fan could result in small airborne droplets from a resident’s sneeze or cough to disperse towards the face of a worker. For this reason, a well-balanced mechanical ventilation system is an essential control during an outbreak of respiratory disease.

Joint Health and Safety Committees and locals should evaluate the current heating, ventilation and air conditioning (HVAC) systems on a case by case basis to determine if a personal comfort device is contributing or reducing the spread of COVID-19. Included below are key considerations to keep in mind.

Legislation

An employer has the broad duty to take every precaution reasonable in the circumstance to protect a worker. This duty, under section 25 (2) (h) of the Act, can apply to the standards adopted for ventilation systems. Generally, the function and design of HVAC systems of buildings in Ontario should conform to the standards from the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE).

The Act, under section 25 (1) (b) and (d), requires that prescribed devices and equipment be in good condition and used in the workplace, respectively. See subsection 25 (1) and (2) of the Act, Duties of Employers HERE.

The Health Care and Residential Facilities regulation sets out specific duties of the employer for ventilation systems. See section 19 and 20 of the Regulation HERE

Key considerations from the Regulation are:

1. The means of indoor ventilation, whether mechanical or natural, must protect the worker.
2. A qualified person must inspect a mechanical system at least every six (6) months. The inspection shall include a report which must be shared with the JHSC.
3. The ventilation system must supply uncontaminated air to replace exhausted air.
4. The system to bring air into the workplace, either natural (windows) or mechanical (HVAC, fans), shall enter in a manner that does not cause undue drafts, blowing of settled dust, and interference with any exhaust system.

In light of the current pandemic, all health care settings should already have had their ventilation systems inspected, despite the 6-month interval, as noted in the Regulation mentioned above. The requirements of the inspection are found on the Ministry of Labour, Training and Skills Development website HERE.

Assessment of the Ventilation Systems

Essential to any system is to ensure that no other equipment or device interferes with the capacity of an HVAC system to operate correctly. Fans and open windows in homes with central HVAC systems have the potential to cause undue drafts that can further contaminate the area or spread the virus into a hallway or other rooms.

A ventilation system can be modified to ensure a greater supply of outside air while reducing the recirculation of air inside the workplace. Any modification or balancing of a system must be done by a qualified person.

There have been cases of coronaviruses that were spread by improper ventilation. In the article below, the air currents for an air conditioning unit blew towards the individuals and mostly drove air currents (and the COVID suspended/droplets in air) that could spread the contamination to all the surfaces in that current. We would expect similar results if a fan was present in a room.

https://wwwnc.cdc.gov/eid/article/26/7/20-0764_article

A risk assessment is required when new hazards or new circumstances exist. As such, employers must assess if the current system is adequately protecting workers from exposure to COVID-19 inside or outside of an isolated room or cohort area. Consultation with the JHSC must take place on the development and implementation of the assessment. A guide to hazard prevention programs and risk assessments are available on the CUPE Health & Safety page HERE.

If an employer wants to permit fans or similar devices, though we would strongly urge against them, we suggest that the approval is based on the results of the risk assessment on the spread of COVID-19 with the use of those devices. Their use should discontinue while workers are present. The employer must seriously consider this question on a case by case basis before approving them, with consideration to the following:

• How does the machine work and how does it change air currents in its vicinity?
• What is the COVID burden in the facility/neighbourhood/geographic area? (Much higher risks in Toronto than in Sudbury, for example.) 
• How is contact inside the facility and outside managed? (What’s the risk if a symptomatic carrier/patient comes in? Do residents roam freely?)
• What’s the cleaning/decontamination protocol?
• What are the PPE that staff are using when in the area?

Resources:

CUPE COVID-19 Resources

https://cupe.ca/covid-19

CUPE Resources for Joint Health and Safety Committees

https://cupe.ca/health-and-safety-committee-resource-kit

Morawska, et al. How can airborne transmission of COVID-19 indoors be minimized?
Environment International (2020)

https://doi.org/10.1016/j.envint.2020.105832

Interim guidance on the use of cooling stations – (subsidizing in-home AC and working with utility companies to prevent utility shut-off during this period).

https://www.cdc.gov/coronavirus/2019-ncov/php/cooling-center.html

Interim guidance for reopening that mentions disabling on-demand ventilation.

https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html