- Safety and Health Topics
This section highlights OSHA standards and directives (instructions for compliance officers) that may be applicable in the event of possible worker exposure to Bacillus anthracis (BA), which causes anthrax.
Employers whose workers will be involved in emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard must comply with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120). This may include emergency response following an anthrax incident. Instruction CPL 02-02-073 describes OSHA enforcement procedures under the relevant provisions of the HAZWOPER standard.
The U.S. Environmental Protection Agency (EPA) has promulgated a standard applying OSHA's HAZWOPER standard to state and local government workers in states where there is no OSHA-approved State Plan. See 40 CFR Part 311.
OSHA's HAZWOPER Safety and Health Topics page explains requirements of the OSHA HAZWOPER standard, including required worker training.
In situations with potential worker exposure to bioaerosols containing BA spores, including environmental releases, employers must also follow OSHA's Respiratory Protection standard (29 CFR 1910.134).
Other elements of infection control for BA are covered under OSHA's Personal Protective Equipment (PPE) standards (29 CFR 1910 Subpart I) and Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), often referred to as the "General Duty Clause." Section 5(a)(1) requires an employer to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." At times, OSHA uses the General Duty Clause to address hazards for which there are no specific standards (e.g., occupational exposure to BA).
Employers also must protect their workers from exposure to chemicals used for cleaning and disinfection. Where workers are exposed to hazardous chemicals, employers must comply with OSHA's Hazard Communication standard (29 CFR 1910.1200) and other applicable OSHA chemical standards. In labs, that may include the Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450). In addition, OSHA recommends that employers consult CDC guidance in order to implement a comprehensive worker protection program.
Paragraph 11(c) of the OSH Act, 29 USC 660(c), prohibits employers from retaliating against workers for raising concerns about safety and health conditions. OSHA encourages workers who suffer such discrimination to submit a complaint to OSHA. Workers must file such complaints within 30 days.
Depending on the specific work task, setting, and exposure to biological or chemical agents, the following OSHA standards may apply (note that this listing by CFR part/standard number includes the standards described above):
General Industry Standards (29 CFR 1910)
- 1910 Subpart E, Means of Egress
- 1910.38(a), Emergency Action Plans
- 1910 Subpart H, Hazardous Materials
- 1910.120, Hazardous waste operations and emergency response.
- 1910 Subpart I, Personal protective equipment (PPE)
- 1910.132, General requirements [related topic page]
- 1910.133, Eye and face protection [related topic page]
- 1910.134, Respiratory protection [related topic page]
- Appendix A, Fit testing procedures (Mandatory)
- Appendix B-1, User seal check procedures (Mandatory)
- Appendix B-2, Respiratory cleaning procedures (Mandatory)
- Appendix C, OSHA respirator medical evaluation questionnaire (Mandatory)
- Appendix D, Information for workers using respirators when not required under standard (Mandatory)
- 1910.138, Hand protection
- 1910 Subpart J, General environmental controls
- 1910.141, Sanitation
- 1910 Subpart K - Medical and First Aid
- 1910.151, Medical services and first aid
- 1910 Subpart Z, Toxic and hazardous substances [related topic page]
- 1910.1020, Access to employee exposure and medical records (See also: 29 CFR 1904, Recording and reporting occupational injuries and illness)
- 1910.1030, Bloodborne pathogens
- Appendix A, Hepatitis B Vaccine Declination (Mandatory)
- 1910.1200, Hazard Communication [related topic page]
- Appendix A, Health Hazard Criteria (Mandatory)
- Appendix B, Physical Hazard Criteria (Mandatory)
- Appendix C, Allocation of Label Elements (Mandatory)
- Appendix D, Safety Data Sheets (Mandatory)
- Appendix E, Definition of "Trade Secret" (Mandatory)
- Appendix F, Guidance for Hazard Classifications Re: Carcinogenicity (Non-Mandatory)
- 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories
Agriculture Standards (29 CFR 1928)
- Inspection procedures for the Respiratory Protection Standard. CPL 02-00-158, (June 26, 2014). Establishes agency interpretations and enforcement policies, and provides instructions to ensure uniform enforcement of the Respiratory Protection standard (29 CFR 1910.134).
- Enforcement Guidance for Personal Protective Equipment (PPE) in General Industry. CPL 02-01-050, (October 2, 2011). Establishes OSHA's general enforcement and guidance policy for its standards addressing PPE. It instructs OSHA enforcement personnel on both the agency's interpretations of those standards and the procedures for enforcing them.
- Rules of agency practice and procedure concerning OSHA access to employee medical records. CPL 02-02-072, (August 22, 2007). Provides guidance to OSHA personnel concerning application of the rules of agency practice and procedure set forth at 29 CFR 1913.10 when accessing personally identifiable employee medical records. Also presents guidance concerning Assistant Secretary authorization to conduct limited review of specific employee medical information when OSHA standards require such information and there is a need to gain access for the purpose of determining compliance.
- Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases. CPL 02-02-073, (August 27, 2007). Updates policies and provides clarification to ensure uniform enforcement of paragraph (q) of the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) (29 CFR 1910.120 and, in construction, 29 CFR 1926.65), which covers emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
- Recordkeeping Policies and Procedures Manual. CPL 02-00-135, (December 30, 2004). Transmits enforcement information and provides changes and additions to CPL 02-00-131/CPL 2-0.131 of January 1, 2002, Chapter 1; Paragraph V; Federal Program Changes; and Chapter 5, Frequently Asked Questions on OSHA's recordkeeping regulations.
- Inspection Procedures for the Hazard Communication Standard. CPL 02-02-079, (July 9, 2015). Establishes policies and provides clarifications to ensure uniform enforcement of the Hazard Communication standard (HCS).
- Field Operations Manual (FOM). CPL 02-00-160, (August 2, 2016). Provide OSHA offices, State Plan programs and federal agencies with policy and procedures concerning the enforcement of occupational safety and health standards. Also, this instruction provides current information and ensures occupational safety and health standards are enforced with uniformity