- Safety and Health Topics
This section highlights OSHA standards and the preamble to OSHA's Bloodborne Pathogens (BBP) standard (29 CFR 1910.1030), directives (instructions for compliance officers), and a Memorandum of Understanding, all of which may be applicable in the event of possible worker exposure to MERS-CoV.
Elements of infection control for MERS-CoV, including a number of precautions for diseases for which the route(s) of transmission may be uncertain, are covered under OSHA's PPE standards (29 CFR 1910 Subpart I), the BBP standard (29 CFR 1910.1030), as well as 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 employers to furnish to each worker "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." At times, OSHA uses the General Duty Clause to address hazards for which there are no specific standards (e.g., occupational exposure to MERS-CoV).
Consult the CDC guidance Interim Infection Prevention and Control Recommendations for Hospitalized Patients with Middle East Respiratory Syndrome Coronavirus (MERS-CoV) to determine appropriate protections for healthcare workers exposed to MERS-CoV. The CDC's MERS web page describes MERS-specific infection control practices and PPE for healthcare and other workers.
When there is potential for worker exposure to bioaerosols containing MERS-CoV, employers must also follow OSHA's Respiratory Protection standard (29 CFR 1910.134). The Background and Control and Prevention tabs provide additional information about potential aerosol exposure hazards and controls.
Employers must also 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 addition, OSHA recommends that employers consult CDC guidance in order to implement a comprehensive worker protection program. The OSHA Hospital e-Tool contains a section on Housekeeping, including information on hazardous chemicals used in hospitals and related OSHA standards.
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 have 30 days to file their complaints.
Depending on the specific work task, setting, and exposure to biological or chemical agents, some OSHA standards that may apply include:
General Industry (29 CFR 1910)
- 1910 Subpart I, Personal protective equipment (PPE)
- 1910.132, General requirements [related topic page]
- 1910.133, Eye and face protection [related topics 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 employees using respirators when not required under standard (Mandatory)
- 1910.138, Hand protection
- 1910.141, Sanitation
- 1910.151(c), Medical Services and First Aid
- 1910 Subpart Z, Toxic and hazardous substances [related topic page]
- 1910.1020, Access to employee exposure and medical records
- Also see 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illness
- 1910.1030, Bloodborne Pathogens [related topic page]
- 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)
Preambles to Final Rules
- 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, (February 10, 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 worker medical records. Guidance is also provided concerning authorization by the Assistant Secretary to conduct limited review of specific worker medical information when OSHA standards require such information and there is a need to gain access to determine compliance.
- Recordkeeping Policies and Procedures Manual. CPL 02-00-135, (December 30, 2004). Transmits enforcement information on OSHA's recordkeeping regulations.
- Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens. CPL 02-02-069, (November 27, 2001). Establishes policies and provides clarification to ensure that uniform inspection procedures are followed when conducting inspections to enforce the Occupational Exposure to Bloodborne Pathogens standard.
- See also Most Frequently Asked Questions Concerning the Bloodborne Pathogens Standard, 1910.1030. Provides answers to the most commonly asked questions related to the Bloodborne Pathogens standard.
- 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).
Memorandum of Understanding (MOU) and OSHA's enforcement of the working conditions of aircraft cabin crewmembers
- Information on Memorandum of Understanding between OSHA and the U.S. Department of Transportation (DOT), Federal Aviation Administration (FAA) on Flight Attendant/Cabin Crewmembers Health and Safety. In general, the safety and health of aircraft cabin crewmembers and flightcrew members are under the jurisdiction of the FAA and not covered by OSHA standards while they are on aircraft in operation. However, under a policy statement issued by FAA and a Memorandum of Understanding (MOU) between the FAA and OSHA, Occupational Safety and Health Standards for Aircraft Cabin Crewmembers, aircraft cabin crewmembers are covered by the following standards onboard aircraft in operation:
As defined in the FAA policy statement, an aircraft cabin crewmember means a person assigned to perform duty in an aircraft cabin when the aircraft is in operation (other than flightcrew members). Aircraft cabin crewmembers include flight attendants, workers assigned to clean and restock the cabin, and other workers assigned to perform duty in an aircraft cabin when the aircraft is in operation. These workers, and baggage handlers, are covered by all OSHA standards when they are not working in an aircraft cabin when the aircraft is in operation.
For the purpose of the MOU and the policy statement, an aircraft is "in operation" from the time it is first boarded by a crewmember, preparatory to a flight, to the time the last crewmember leaves the aircraft after completion of that flight, including stops on the ground during which at least one crewmember remains on the aircraft, even if the engines are shut down.
- Under section 4(b)(1) of the Occupational Safety and Health Act, 29 USC 653(b)(1), OSHA generally does not have authority to enforce the standards not encompassed in the MOU (e.g., the PPE standard) with respect to the working conditions of aircraft cabin crewmembers while they are onboard aircraft in operation. The FAA, and not OSHA, generally has authority over those working conditions.
- Separate from the MOU, OSHA has authority to enforce its regulations on recordkeeping, 29 CFR Part 1904, and access to employee exposure and medical records, 29 CFR § 1910.1020, to investigate employee complaints of discrimination for engaging in protected activity related to safety or health in the workplace under section 11(c) of the OSH Act, 29 U.S.C. § 660(c), and to investigate employee complaints of discrimination for providing information about alleged violations of FAA requirements or of any Federal law relating to air carrier safety under section 519 of the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century, Pub.L. 106-181, 49 U.S.C. § 42121.
- Additional information is available in an OSHA Memorandum for Regional Administrators, "Applicability of Certain OSHA Standards to Cabin Crew Members on Aircraft in Operation."