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Health and Safety Plan (HASP) requirements for anthrax-contaminated sites

Anthrax CollageFor cleanup operations, OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120) requires a written health and safety plan (HASP), which identifies site hazards and appropriate controls to protect employee health and safety. The recommended elements addressed below meet or exceed the intent of a site-specific HASP as described in the standard, 1910.120(b)(4): Due to overlap of some of the elements, it may be useful to expand the HASP to include those elements necessary to protect the local community and environment (for example, disposal of waste from decontamination, monitoring community exposures to fumigants).

Organizational Structure
The organizational structure part of the program shall establish the specific chain of command and specify the overall responsibilities of supervisors and employees. It shall include, at a minimum, the following elements:
  • A general supervisor who has the responsibility and authority to direct all hazardous waste operations.

  • A site safety and health supervisor who has the responsibility and authority to develop and implement the HASP and verify compliance.

  • All other personnel needed for hazardous waste site operations and emergency response and their general functions and responsibilities.

  • The lines of authority, responsibility, and communication.
The organizational structure shall be reviewed and updated as necessary to reflect the current status of waste site operations. It is necessary to organize and assign personnel roles, responsibilities, lines of authority, and communication before an anthrax-related event to ensure an efficient and safe response.

For more detailed information regarding specific roles associated with an emergency response, go to the Anthrax eTool Training page.

Site Characterization and Job Hazard Analysis
Job Hazard AnalysisThe HASP requires a characterization of the site-specific job hazards, including:
  • Location and approximate size of the site,

  • Description of the response activity and the job task to be performed,

  • Duration of the planned employee activity,
  • Site topography and accessibility by air and roads,

  • Safety and health hazards expected at the site (for example, chemical, physical, biological hazards),

  • Pathways for hazardous substance spread, and

  • Present status and capabilities of emergency response teams that would provide assistance to hazardous waste cleanup site employees at the time of an emergency.
The following links provide additional information regarding site characterization and job hazard analysis:

Site Control
DangerIn the event of an anthrax release, it is necessary to control site access in order to prevent exposure and spread of the anthrax spores. Suggested site controls include:
  • Evacuate and secure the area,

  • Turn off fans and air handling systems, if possible, and

  • Notify personnel about the potential hazard and to not access the area. The impacted area should only be accessed by those trained and informed about the release.
As outlined in the HAZWOPER (29 CFR 1910.120), a site control program for protecting employees should be part of the employer's HASP and should include, at a minimum, the following:
  • Site map,

  • Site work zones,

  • Use of a "buddy system,"

  • Site communications including alerting means for emergencies,

  • Standard Operating Procedures (SOPs) or safe work practices, and

  • Identification of the nearest medical assistance.

TrainingA site-specific training program ensures that workers receive the hazard awareness training they need to work safely. Training should be based on the job hazard analysis in the HASP and other applicable standards. Anthrax-specific hazard awareness training should help workers understand the health hazards of anthrax and how to protect themselves from exposure to spores. Specific topics might include:
  • How workers might be exposed to spores, the signs and symptoms of infection, and medical conditions that could place them at increased risk (such as a compromised immune system),

  • Where contamination has been identified in the facility, and the status of decontamination of those areas, and

  • How to minimize the risk of disease through specific standard operating procedures and controls (such as engineering controls, work practices, housekeeping, or PPE), and whether specific measures are expected to be temporary or permanent.
49 CFR Part 172, Subpart H provides additional training requirements for workers preparing contaminated materials or other hazardous materials for transport. For the most current version of 49 CFR, visit the: Code of Federal Regulations website.

Additional training information is provided on the Anthrax eTool Training page.

Medical Surveillance
Medical SurveillanceThe purpose of medical surveillance in the workplace is to improve the effectiveness of the occupational health and safety program by systematically collecting and analyzing information that pertains to at-risk workers.

Medical screening is the use of examinations or tests to detect adverse effects on a worker's health at an early stage when prevention is possible or treatment is most effective.
  • Baseline medical screening should identify pre-existing conditions that may affect an individual worker's fitness for duty.

  • When it is no longer necessary for a worker to re-enter a contaminated site, a final evaluation should be done to identify changes from the baseline and any new risk factors.
Further information about Medical Surveillance may be found at the following websites:

Personal Protective Equipment
Personal Protective EquipmentPersonal protective equipment (PPE) shields or isolates workers from health and safety hazards in the workplace.  In a site where anthrax spores may be present, PPE protects workers from exposure to respiratory and skin hazards and prevents the spread of contaminants to uncontaminated areas. The level and type of PPE should be based on the job hazard analysis in the HASP.  Workers should be trained on the location, type, and proper use of the PPE.

Further information about PPE may be found at the following websites:

Exposure Monitoring
For exposure monitoring, the HASP should include the following three major components:
  • Medical measures to prevent anthrax,

  • Medical screening and follow-up care for anthrax and medical complications related to preventive measures, and

  • Knowledge and information that workers need to prevent anthrax and medical complications related to preventive measures.

Temperature Extremes
Temperature ExtremesHeat Stress: Temperature extremes can adversely affect worker health and safety. Heat stress can be experienced by workers due to hot ambient temperatures. In addition, the use of PPE, especially in excess, can increase the chance a worker will experience heat stress. The four main types of heat stress are listed below:
  • Heat Rash:  Caused by continuous exposure to heat and humid air and aggravated by chafing clothing. Decreases ability to tolerate heat, as well as being a nuisance.

  • Heat Cramps:  Caused by profuse perspiration with inadequate fluid intake and chemical replacement. Signs are muscle spasms and pain in the extremities and abdomen.

  • Heat Exhaustion:  Caused by increased stress on various organs to meet increased demands to cool the body. Signs are shallow breathing; pale, cool, moist skin; profuse sweating; and dizziness and physical or mental exhaustion.

  • Heat Stroke:  The most severe form of heat stress. Body must be cooled immediately to prevent severe injury and/or death. Signs are red, hot, dry skin; no perspiration; nausea; dizziness and confusion; strong, rapid pulse; coma. Medical help must be obtained immediately.
Cold Stress:  Cold stress can be experienced by workers when they are exposed to a cold environment.  The two main types of cold stress are listed below:
  • Frostbite: Local injury resulting from cold is included in the generic term frostbite. There are several degrees of damage. Frostbite of the extremities can be categorized into:
    1. Frost nip or incident frostbite - the condition is characterized by sudden blanching or whitening of skin.
    2. Superficial frostbite - skin has a waxy or white appearance and is firm to the touch, but tissue beneath is resilient.
    3. Deep frostbite - tissues are cold, pale and solid; extremely serious injury.
  • Hypothermia: There are degrees of hypothermia which are characterized as "moderate" and "severe." A victim of moderate hypothermia exhibiting the first seven signs listed below is still conscious but often confused. Severe hypothermia is determined by extreme skin coldness, loss of consciousness, faint pulse, and shallow, infrequent, or apparently absent respiration. Death is the ultimate result.
    1. Severe shivering
    2. Abnormal behavior
    3. Slowing
    4. Stumbling
    5. Weakness
    6. Inability to walk
    7. Collapse
    8. Stupor
    9. Unconsciousness

Spill Containment
To prevent further spread of the anthrax spores:
  • Evacuate and secure the area.

  • Turn off the air handling systems, if possible.

  • Notify personnel to stay away from the site. Only those trained and informed about the release should access the impacted area.

DecontaminationCleaning an area or item contaminated by anthrax involves numerous and variable issues that are specific to individual locations. No single technology, process, or strategy will be effective in every case. Responders must develop a decontamination plan that takes into account the:
  • Nature of the contamination.

  • Extent of the contamination.

  • Objectives of decontamination.
The extent of contamination and how the contamination was spread are critical considerations in isolating affected areas and selecting appropriate decontamination technologies.

Emergency Response
Emergency ResponseNotify the agencies below. Keep the contact numbers easily accessible.
  • Call 9-1-1 for local police assistance and the local Federal Bureau of Investigations (FBI).

  • Call the National Response Center (NRC) at (800)424-8802.  The NRC will notify the appropriate agencies.
An emergency response protocol should be contained in the HASP for site personnel to follow while waiting and preparing for the notified agencies to arrive, initial actions should focus on the following:
  • Isolate contaminated areas,

  • Minimize exposure to others, and

  • Keep track of those who may have been exposed.
Standard Operating Procedures
Developing standard operating procedures (SOPs) provides a guideline for personnel to perform work activities as well as proper response as outlined in the HASP. Easily accessible SOPs can prevent mistakes and incorrect protocol, and therefore result in a safer workplace. Procedures directly related to an anthrax-related threat that may be included in the SOPs are: Additional information about evacuation procedures can be found in OSHA's Evacuation Plans and Procedures eTool.

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