- The employer is notified by law enforcement or public health authorities that a facility is strongly suspected of or confirmed as having been contaminated with anthrax spores.
- The employer is engaged in emergency response to and clean-up of bio-terrorist releases of anthrax spores.
Actions taken by an employer under these circumstances may vary depending on the specific facts and the nature of the incident. Employers should follow instructions given by law enforcement and public health agencies and convey appropriate information to employees.
Emergency Responders, Clean-up Personnel, and Investigators
Recommended Work Practices
- Emergency response to, and investigation and clean-up of sites contaminated through bio-terrorist acts is specialized work that must be performed by highly trained and qualified personnel.
- OSHA's Hazardous Waste Operations and Emergency Response Standard, also known as HAZWOPER, (29 CFR 1910.120) applies to these operations. The HAZWOPER standard protects workers who respond to uncontrolled or emergency releases of hazardous substances and clean-up of sites contaminated with these substances. Under the standard, the definition of hazardous substances includes both chemicals and biological agents, and a bacterium like anthrax, which can cause disease and death, is covered under the definition.
- The HAZWOPER standard provides protection through common sense requirements like emergency planning, training, exposure monitoring, and exposure control through protective measures such as work practices and personal protective equipment (PPE).
- HAZWOPER requirements are performance-oriented and are based on the risk an employer anticipates his/her employees will face. Each employer should review the requirements and choose the best way to apply them to specific emergency or clean-up operations.
Like the other requirements under HAZWOPER, the PPE requirements are performance-oriented. This means that the level of protection chosen, and the PPE used should be proportional to the risk anticipated for the task workers will do. OSHA provides the following recommendations, which are based on our recent experience with workplaces contaminated with anthrax spores. In most recent instances, exposure has generally resulted from contact with or dispersal of anthrax spores from a contaminated letter or package. As a result, many workers investigating suspected releases or cleaning up these types of releases may be able to respond in Modified Level C protection, outlined in Number 1 below. Terrorist releases of anthrax spores where there is no information about the potential source or dispersal method, or where the release is still occurring, will require that workers respond in higher levels of protection, as outlined in Numbers 2-3 below.
- Modified Level C protection should be adequate during the investigation and clean-up of a known anthrax release where the agent was dispersed from a letter or package that can be easily bagged and there is no potential for splashing potentially contaminated materials. Modified Level C cannot be used if anthrax spores were dispersed using an aerosol-generating device, like a garden duster, or there is no information about how anthrax spores were released. Modified Level C should be consistent with the description in HAZWOPER Appendix B, but employees should wear a tight-fitting, full-face Powered Air-Purifying Respirator (PAPR) and skin protection with an integral hood and booties. Note: Selection of respiratory protection should be consistent with OSHA's Respiratory Protection Standard (29 CFR 1910.134) and take into account the agents used for decontamination. If organic vapor cartridges are used, then a cartridge change schedule should be implemented.
- Level B protection should be adequate during response to or clean-up of a release where anthrax spores may have been dispersed with an aerosol-generating device but are no longer being released, or where there is a high potential for splashing potentially contaminated materials. Level B protection is a PPE ensemble that provides the highest level of respiratory protection, but a lesser level of skin protection than Level A. Level B protection should be consistent with the description in HAZWOPER Appendix B.
- Level A should be adequate for response to or clean-up of a release that involves an unknown dispersal method. Level A protection should also be adequate during response to or clean-up of a release that involves an aerosol-generating device and the release is still occurring, or the release has stopped but there is no information about the duration of the release or the airborne concentrations of anthrax spores. Level A protection is a PPE ensemble that provides the greatest level of skin, respiratory, and eye protection. Level A protection should be consistent with the description in HAZWOPER Appendix B.
- Personnel assisting in decontamination of emergency responders or clean-up personnel should be in PPE that is equivalent to one level below that required for the responder or clean-up personnel (e.g., if responder in Level A, then decontamination personnel in Level B).
- OSHA Anthrax Fact Sheet
- OSHA Standard for General Requirements for Personal Protective Equipment, 1910.132
- OSHA Standard for Respiratory Protection, 1910.134
- OSHA Standard for Hand Protection, 1910.138
- Technical Links Webpages for Emergency Response, Respiratory Protection and PPE
- OSHA Instruction CPL 2-2.59A Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases.
- Inspection Procedures for the Respiratory Protection Standard.
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