- Safety and Health Topics
This section highlights OSHA standards, documents and other standards 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 (29 CFR 1910)
Subpart E – Means of Egress
1910.38(a), Emergency action plans
|Subpart H – Hazardous Materials||1910.120, Hazardous waste operations and emergency response|
|Subpart I – Personal Protective Equipment||1910.132, General requirements|
|1910.133, Eye and face protection|
|1910.134, Respiratory protection|
|1910.138, Hand protection|
|Subpart J – General Environmental Controls||1910.141, Sanitation|
|Subpart K – Medical and First Aid||1910.151, Medical services and first aid|
|Subpart Z – Toxic and Hazardous Substances||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|
|1910.1200, Hazard communication|
|1910.1450, Occupational exposure to hazardous chemicals in laboratories|
Agriculture (29 CFR 1928)
|Subpart I – General Environmental Controls||1928.110, Field sanitation|
Note: The “Directives” bullets above link to directives related to each OSHA standard. The directives in this list provide additional information that is not necessarily connected to a specific OSHA standard highlighted on this Safety and Health Topics page.
- 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.
- 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.
There are twenty-eight OSHA-approved State Plans, operating state-wide occupational safety and health programs. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or more stringent requirements.
The California Division of Occupational Safety and Health (Cal/OSHA) Aerosol Transmissible Diseases (ATD) standard is aimed at preventing worker illness from infectious diseases that can be transmitted by inhaling air that contains bacteria (including BA and its spores), or other disease-causing organisms. While the Cal/OSHA ATD standard is mandatory for certain healthcare employers only in California, it may provide useful guidance for protecting other workers exposed to BA spores.