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106 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS 6 Principal Elements of an Occupational Health and Safety Program Most institutions have developed effective programs for controlling hazards and minimizing occupational risks of injury and illness in the workplace. The motivation for and commitment to conducting occupational health and safety programs are derived from two principal sources: a moral obligation to safeguard employees from unnecessary risks and a regulatory requirement that employers provide a safe and healthful workplace for their employees. Many institutions that maintain an animal care and use program have an environmental health and safety office that involves people with expertise in chemical safety, biological safety, physical safety, industrial hygiene, health physics, engineering, environ- mental health, occupational health, fire safety, and toxicology or have corre- sponding technical resources available under other arrangements. The environ- mental health and safety office generally provides technical consultation, risk assessment, accident reviews, training, emergency response, waste management, recordkeeping, inspections and audits, and compliance monitoring. Those ser- vices assist institutional leaders and managers of the animal care and use activi- ties in establishing health and safety policies and promoting high standards of safety. Services provided by the environmental health and safety office can be most helpful, however, when they are designed in collaboration with the institu- tional leaders, managers, and employees so as to ensure that the occupational health and safety program not only complies with regulations but is relevant and practical for the animal care and use program. There are nine key elements of effective occupational health and safety programs: administrative procedures, facility design and operation, exposure con- trol, education and training, occupational health-care services, equipment perfor- 106
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 107 mance, information management, emergency procedures, and program evalua- tion. All but occupational health-care services are discussed in this chapter. The occupational health-care services are often the most difficult for an institution to plan and carry out because consensus on what needs to be done has not yet been established. This important element is discussed separately in Chapter 7. ADMINISTRATIVE PROCEDURES Adequate administrative procedures are vital to the success of an occupa- tional health and safety program. Administrative procedures are most effective if developed in collaboration with their users, and both managers and employees need to know their roles. Approval mechanisms established to authorize research activity should be clear, practical, and well publicized. Procedures should be developed for conducting a health and safety review of research activities that involve infectious agents, recombinant-DNA molecules that are not exempt from federal guidelines, hazardous chemicals, radiation, or the use of animals that present unique hazards. Those procedures should be incorporated into the institutional animal care and use committee (IACUC) project-review process. An appropriate environmental health and safety profes- sional can serve on the committee to participate in the review or be otherwise involved in the review process. Where substantial risks exist, researchers should be encouraged to incorporate health and safety procedures as an integral part of the research plan. FACILITY DESIGN AND OPERATION During the design of a new facility or the renovation of an existing one, hazards associated with the care and use of animals should be addressed in a collaborative effort involving investigators who will use the facility, the manager and other principal staff of the institutionâs animal care and use program, and environmental health and safety staff. The design process begins with defining the species of animals expected to be housed in the facility and the nature of the research programs that will use them. Thorough consideration of hazards is nec- essary to ensure that the design will allow compliance with federal, state, and local government safety requirements and meet relevant accreditation standards. For example, adequate space should be made available for storage of hazardous materials and for the collection, storage, and processing of wastes. The potential users, the manager of the animal care and use program, a representative of the environmental health and safety staff, the building engineer, and the architect should remain involved in the design and construction process until completion. Special consideration should be given to the ventilation system, space ar- rangement and layout, support areas, traffic patterns, and access to utilities and mechanical areas. Criteria for selecting mechanical systems and equipment should
108 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS be based on reliability, operational integrity, projected length of service, and ease of maintenance. The selection of space, layout of equipment, work surfaces, and traffic patterns will influence the operational effectiveness of the facility and the ease with which staff can maintain established administrative procedures for operating the facility safely. A program of preventive maintenance will ensure continued safe operation of a well-designed facility; this is an important aspect of occupational health and safety, particularly when efforts to minimize substantial risks require the use of engineering controls. Careful attention should be given to prevention and control of ergonomic hazards in the design of animal facilities (NRC 1996). Engineering controls that reduce physical stress in repetitive operations and in the lifting and movement of heavy loads by animal care staff are important design objectives. Ergonomic design criteria should be used in the selection of fixed equipment, such as animal caging, necropsy tables, and sinks. Several authoritative references are available which provide comprehensive coverage of this important subject (CCAC 1993, DiBerardinis and others 1993, NRC 1996, Ruys 1991). EXPOSURE CONTROL METHODS Exposures to occupational hazards are controlled through the application of engineering controls, work practices, and the use of personal protective equip- ment. Those measures are used in a hierarchical structure. That is, it is first attempted to isolate workers from hazards with engineering controls. If engineer- ing controls do not adequately control the exposure potential, work practices are modified to help to minimize exposure potential. Finally, personal protective equipment might be required to provide a barrier between employees and hazards that cannot be otherwise controlled. Engineering Controls Engineering controls are a combination of safety equipment and physical features of the facility that help to minimize hazardous exposures of personnel and the surrounding environment. Safety equipment provides a barrier between employees and hazards, and physical features can prevent or reduce the potential for release of hazardous agents from the immediate work area. Some engineering controls commonly used in animal care and research are barriers and airlocks, chemical fume hoods, biological safety cabinets, and isolation cages. Barriers help to confine potential contamination to areas where it is gener- ated and to control access to these areas. In animal biosafety level 3 facilities (see Table 3-4), barriers isolate animal areas from other, adjacent areas. The principal barriers are exhaust air ventilation systems that provide directional airflow, archi- tectural barriers that control access to the animal facility, and airlocks that help to maintain air pressure differentials to ensure the proper direction of airflow. Ac-
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 109 cess control barriers also have value for any animal facility because they can be used to prevent unauthorized people from entering the animal facility; this kind of control is difficult to accomplish without constructing an access foyer or special entrance area through which authorized people must pass before entering the facility. Chemical fume hoods are local exhaust devices that help to prevent toxic, offensive, and flammable vapors or dusts from entering a work area (DiBerardinis and others 1993, NRC 1995). They provide employee protection from such haz- ards as chemical spills, splashes or sprays, other accidentally released materials, fires, and minor explosions. Hoods should be properly located in the laboratory away from doors, supply air ducts, and high traffic areas. Hoods should be evaluated before use to ensure adequate face velocities (typically 80-100 ft/min) and the absence of excessive turbulence (NRC 1995). The hood installation should include a continuous airflow monitoring device to allow the user to check operat- ing conditions before conducting hazardous procedures. If inadequate hood per- formance is suspected, correct operation should be verified before the hood is used. The hood sash opening should be kept as narrow as reasonably practicable to improve the overall performance of the hood. The containment capability of hoods is also influenced by the amount and placement of equipment in the hood, persons walking by the hood, and the opening and closing of doors. Careful technique by the user is essential in achieving optimal performance. Biological safety cabinets are among the most effective, as well as the most commonly used, primary containment devices for work with infectious agents. Several types of cabinets are available, and authoritative references should be reviewed before a cabinet is selected for a particular experimental use (CDC-NIH 1993, Fleming and others 1995, Kruse and others 1991). As with any piece of laboratory equipment, personnel should be trained in the proper use of biological safety cabinets. Air balance and inward airflow are critical in the safe operation of these cabinets. Biological safety cabinets should be certified in accordance with the National Sanitation Foundation Standard 49 (NSF 1992). Containment can be compromised by interruption in airflow caused by insertion and removal of a workerâs arms through the work opening, opening and closing of room access doors, and movement of staff near the cabinet. Fans, heating and air conditioning diffusers, and other air-handling devices near the cabinet can also disrupt airflow patterns. Biological safety cabinets have been configured to pro- vide containment space for cleaning cages. They can protect both the animals and personnel from exposures to aerosols that are generated by cleaning procedures. Cage filter tops are used in animal research to prevent cross contamination with infectious agents. They prevent transmission of agents between and among animals and people by preventing particles from entering the cage. Isolation cages with filter tops that fit tightly to the cage rim can constitute an effective barrier to transmission of agents by the aerosol route, but they should be used in
110 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS conjunction with a biological safety cabinet to ensure containment during proce- dures that involve removing the cage top. Ventilated caging systems also control hazards. Exhaust fans create a nega- tive pressure gradient between the cage and the surrounding environment, and exhaust air is filtered with a high-efficiency-particulate-air (HEPA) filter before discharge into the animal room or the building exhaust; this combination can prevent the escape of bioaerosols from the animal environment. Downdraft necropsy tables capture chemical vapors generated during necropsy. The tables are constructed with exhaust fans that produce a downdraft by drawing air through the work surface. Air velocities above the work surface, however, are not sufficient to capture aerosols that are generated by the proce- dure. The protective capacity of these tables can be compromised by air turbu- lence in the room, the size of the animal on the table, and general work practices. Their use should be carefully assessed by knowledgeable health and safety pro- fessionals. Room ventilation is an important engineering control used to maintain com- fortable temperature and humidity in the work area. Changing air continuously can reduce the concentration of airborne contaminants but does not replace the use of such containment devices as chemical fume hoods, biological safety cabi- nets, and filter top cages. A ventilation system that provides directional airflow can prevent the migration of airborne contaminants to unprotected space in the facility. Cage cleaning and cage washing can result in high concentrations of particu- late contaminants and very high heat loads from the cage washing equipment. Consequently, high ventilation rates are important for providing acceptable envi- ronmental conditions for personnel. Local exhaust can be effective in controlling contaminants at the point of generation. Properly engineered and used canopy hoods and flexible exhaust ducts can substantially reduce occupational exposures to such hazards as animal dander and excreta liberated during cage cleaning, aerosols and vapors generated during anesthesia or necropsy, and heat emanating from cage cleaning or waste decontamination. Slot hoods can also be used in controlling these exposures, but their effectiveness depends on the correct static pressure, flow rate, and hood geometry (NRC 1995, p.# 190). Local exhaust devices are particularly useful for controlling emissions from equipment or procedures that cannot reasonably be contained in a hood (De Berardinis and others 1993, p.# 451). Local exhaust devices are not as effective as chemical fume hoods, so engineering and industrial hygiene professionals should be consulted to assist with selection or design for each specific application (NRC 1995, p.# 190). Work Practices Work practices are the most important element in controlling exposures.
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 111 Employees should understand the hazards associated with the procedures that they are performing, recognize the route through which they can be exposed to those hazards, select work practices that minimize exposures, and through train- ing and experience acquire the discipline and skill necessary to sustain profi- ciency in the conduct of safe practices. Several categories of work practices should be considered: â¢ Practices to reduce the number of employees at risk of exposure. â Restrict access to the work area. â Provide warnings of hazards and advice about special requirements. â¢ Practices to reduce exposures by direct and indirect contact. â Keep hands away from mouth, nose, eyes, and skin. â Wash hands when contaminated and when work activity is completed. â Decontaminate work surfaces before and after work and after spills of a hazardous agent. â Use appropriate methods to decontaminate equipment, surfaces, and wastes. â Substitute less-hazardous materials for hazardous materials whenever possible. â Wear personal protection equipment (gloves, gowns, and eye protec- tion). â¢ Practices to reduce percutaneous exposures. â Eliminate the use of sharp objects whenever possible. â Use needles with self-storing sheaths or those designed to protect the user. â Keep sharp objects in view and limit use to one open needle at a time. â Use appropriate gloves to prevent cuts and skin exposure. â Select products with puncture-resistant features whenever possible. â Use puncture-resistant containers for the disposal of sharps. â Handle animals with care and proper restraint to prevent scratches and bites. â¢ Practices to reduce exposure by ingestion. â Use automatic pipetting aids; never pipette by mouth. â Do not smoke, eat, or drink in work areas used for the care and use of research animals. â Keep hands and contaminated items away from mouth. â Protect mouth from splash and splatter hazards. â¢ Practices to reduce exposure by inhalation. â Use chemical fume hoods, biological safety cabinets, and other con- tainment equipment to control inhalation hazards. â Handle fluids carefully to avoid spills and splashes and the generation of aerosols. â Use in-line HEPA filters to protect the vacuum system.
112 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS Handling and Transport of Animals Safety precautions are needed during animal handling and animal transporta- tion to prevent transmission of zoonotic agents to employees. Employees should wear personal protective equipment specifically chosen for the exposures that might be related to the animals being handled or transported. Safety concerns are relevant to all who have access to the animals being transported and those who receive and use them. Personal Hygiene Scrupulous attention to personal hygiene is essential for all personnel who care for and use research animals. They should wash their hands before and after handling animals and whenever protective gloves are removed. There should be no eating, drinking, smoking, application of cosmetics, or other activities that can increase the risk of ingesting hazardous materials or contaminating mucous mem- branes in animal care and animal use areas. Housekeeping All animal care areas, including areas in which hazardous materials are used or stored, should be kept neat and clean. Clutter can become contaminated and add to problems of employee exposure, area decontamination, and waste dis- posal. Work surfaces should be wiped with disinfectant before work begins, immediately after any spill, and at the end of the workday. Floors should be disinfected or decontaminated daily or weekly as appropriate to the potential hazards. Appropriate dust suppression methods should be routinely used. Wet mopping and the use of a HEPA-filtered vacuum cleaner are appropriate for suppressing dust. Waste Disposal Wastes need to be removed at scheduled intervals based on the amount of waste generated and the risk posed by the hazardous agents in the waste material. Planning is required to ensure that sufficient space is available for on-site collec- tion, storage, treatment, and disposal of waste. The disposal of hazardous wastes is subject to federal, state, and local regulations. The environmental health and safety staff should stay informed of regulations, which change often. They should keep all on-site generators of hazardous waste informed of disposal procedures to ensure that they are in compliance with current requirements.
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 113 Restraint of Animals Species specific safe techniques should be used to restrain animals (NRC 1996, p.# 11). Physical restraint might require more than one animal handler. Hand catching of nonhuman primates should be discouraged; use of a pole and capture collar is a safe alternative. The use of mechanical restraint devices or chemical restraints can reduce the potential for escape or injury when animals are being examined or handled. Employees should be aware that physical restraint can increase the inherent risks associated with the animal by intensifying excre- tions, secretions, and aggressive behavior of the animal. Cleaning Cages Caution should be used in removing animals from their cages before cage cleaning to avoid escape. Contaminated shavings, feces, urine, and other poten- tially biohazardous, contaminated, or allergenic materials should be removed with methods that protect the workers (NRC 1996, p.# 43-4). Biological safety cabinets have been designed as bedding dump stations to protect workers from hazardous aerosols that might be generated during cage cleaning. Protective cloth- ing is required to protect workers from contact and percutaneous exposure. The eyes, face, and body should be protected during use of hazardous chemicals. Automatic cage washers pose several problems that should be addressed, includ- ing excess noise that might require hearing protection and ergonomic deficien- cies that might contribute to back injuries and repetitive-motion injuries. Sharp edges on cages and ancillary equipment should be identified and eliminated. Heat in cage washing areas might require changes in ventilation and work practices to avoid excessive heat exposure. Employees should wear appropriate footwear and remain vigilant to the ever-present hazard of wet, slippery surfaces. Personal Protective Equipment The use of personal protective equipment is the final measure for controlling exposures to potentially hazardous agents. Personal protective equipment pro- vides a physical barrier to hazardous materials that might otherwise come into contact with employeesâ skin, eyes, mucous membranes, and clothing. The equip- ment should protect the part of the body that is reasonably expected to come into contact with hazardous agents. Selection should be based on specific knowledge of the potential hazards, experience, and sound professional judgment. Gloves are the most commonly used personal protective clothing. Latex, vinyl, or other appropriate protective gloves should be worn for handling poten- tially contaminated animals or hazardous materials. Care should be taken to ensure that the glove material provides an adequate barrier against the expected hazard. For example, nitrile or rubber gloves might be required to protect against
114 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS some solvents, whereas thick leather would provide better protection against animal bites or scratches. Gloves should be long enough to cover the area to be protected. Disposable vinyl or latex examination or surgical gloves should not be re- used. Heavy duty rubber gloves will hold up well in cleaning and disinfecting; these are of the type commonly used for washing cages. Uniforms, gowns, or laboratory coats are often provided to prevent contami- nation of animal care personnel by animal urine and feces. Such garb should not be worn outside the work area (unless it is covered). Protective clothing should be selected so that it provides an adequate barrier against the type and extent of exposure expected. For example, cage washing personnel might wear heavy rub- ber aprons to protect themselves when using strong detergents and cleaning agents. Safety shoes might be advisable for employees engaged in moving cage carts and other heavy equipment. Similar protective clothing might be needed by those who clean and disinfect animal rooms. The need to decontaminate and dispose of protective equipment is an important consideration in its selection. Reprocessing contaminated laundry can be more expensive than providing dis- posable gowns. Face protection is advised if the eyes, nose, or mouth might be exposed through splashes or splatters of potentially hazardous agents. Safety glasses should be considered minimal eye protection and worn to prevent injury from projectiles, minor splashes, or contact of contaminated hands with eyes. Goggles or face shields might be needed for tasks involving infectious or hazardous liq- uids if there is a potential for splashing and splattering. Goggles or face shields are especially important when disinfectants and cleaning agents are used under pressure. Surgical masks also provide some protection of the mouth from splashes. Respiratory protection might be necessary to control occupational exposures to aerosols. Employees who require respiratory protection should be enrolled in a respiratory program that is in compliance with OSHA standards. The selection and use of proper respiratory protection equipment should be coordinated through the environmental health and safety staff. EDUCATION AND TRAINING Occupational health and safety objectives of an institution can be achieved only if employees know the hazards associated with their work activities; under- stand how the hazards are controlled through institutional policies, engineering controls, work practices, and personal protective equipment; and have sufficient skills to execute safe work practices proficiently. All that requires a multifaceted education and training effort that addresses the full range of health and safety issues related to the care and use of research animals. Approaches for providing an education and training effort depend on the size, resources, animal species,
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 115 research activities, staff experience, and technical expertise of the institution. However, successful programs have three common attributes: â¢ The occupational health and safety goals of the institution and how they will be achieved, including precise guidance on regulatory-compliance strategies, are clearly communicated to all employees. This function is commonly carried out by the environmental health and safety staff through formal orientation, dis- tribution of written guidelines, and periodic refresher training. â¢ Employees are fully apprised of all relevant hazards and control strategies pertaining to their general work assignments. Information provided to employees is developed through the interaction of several key people, including a veterinar- ian or other professional familiar with zoonotic risks presented by the research animals, a health and safety professional who has knowledge of occupational hazards common to animal care and use and relevant hazard control strategies, and scientists who can assess the health risks associated with planned experimen- tation or research protocols. This interaction will define the knowledge needed by employees to protect themselves from hazards associated with their work and point to needs for further training. â¢ Supervisors in the animal care and research groups are actively involved in ensuring that their employees have acquired the necessary skills and attitudes to work safely. If deficiencies are present, on-the-job training supervised by an experienced employee is provided until appropriate standards of proficiency are demonstrated. The involvement of scientists in the development of content for health and safety training is particularly important. Often, employees who routinely care for research animals are not placed under the direct supervision of the scientist who is responsible for the research project, so there can be gaps in communication of information that is necessary to protect the animal care staff or that could correct misperceptions about the risk of the research project. Such gaps could also place research animals at unnecessary risk. For example, research animals might be susceptible to disease when exposed to an animal care employee who is an active carrier of an infectious agent. The health and safety assessments of the scientists need to be conveyed both to the animal care staff and to their supervisors. Their understanding of the research objectives and the attendant hazards will help them to create and maintain a safe work environment in which the animal care staff can be integral and knowledgeable participants in the research activity. Training should be a continuing process. It is best accomplished by identify- ing specific employees in a laboratory or animal care group to serve as a source of information, guidance, and instruction for their colleagues. The designated em- ployees should be kept well informed of institutional health and safety require- ments, safe practices, and relevant research and animal care hazards, and this requires a structured effort whereby the institutional experts in health and safety,
116 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS animal care, and research interact with and advise them on all aspects of the institutionâs occupational health and safety program. Employees who serve in this way should have the recognition, confidence, and genuine support of their supervisors to carry out their important role effectively. The additional health and safety responsibilities are not likely to distract them substantially from the nor- mal daily duties that they were hired to perform. That approach has been successful in many research laboratories. Often, a laboratory manager oversees a laboratoryâs safety program and assigns specific aspects of the program, such as waste management or radiation safety, to other technical staff. The designated employees can serve as mentors and on-the-job trainers for new employees and provide guidance to more experienced workers as the need arises. These duties can be rotated among the experienced staff every several monthsâa practice that can quickly result in a highly informed and skilled workforce. Periodic group meetings are also helpful; they can serve as a forum for refresher training, provide opportunity for open discussion of safety concerns, and be used to review progress in achieving institutional health and safety goals. An effective education and training program requires resources, administra- tive recordkeeping, and a mechanism for monitoring its efficiency, in addition to the interactive and mentoring efforts of key employees who provide relevant health and safety information. Investment of resources will produce a consider- able return. A well-informed staff with safe work habits will minimize occupa- tional injuries and illnesses. That in turn will reduce costs related to labor time, insurance, health care, disability, and legal actions. Recordkeeping is an essential aspect of an education and training program. No program can succeed without knowledge of who needs what training and when such training has been provided. Training records are also required to satisfy specific requirements of federal and state environmental health and safety regulations. The institutionâs official responsible for ensuring maintenance of training records, usually the head of the environmental health and safety office, should strive to establish a simple system that presents the least administrative burden to everyone. A computer-based system should facilitate such an approach. A wide variety of mechanisms exist for evaluating the success of the educa- tion and training program. Among these are site inspections, personnel reviews, injury and illness records, regulatory-compliance citations, and periodic ques- tionnaires. The approach should be carefully designed and applied to provide information useful for both institution officials and employees. EQUIPMENT PERFORMANCE The value of engineering controls in protecting the health and safety of employees depends on the performance and operational integrity of the protec- tive equipment. The environmental health and safety office should include pro-
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 117 grams for certifying and monitoring equipment to ensure that it is capable of providing the necessary protection and maintaining adequate performance. The American National Standards Institute (ANSI) has published consensus guidelines for laboratory ventilation systems (ANSI Standard Z9.5-1993), which include recommendations regarding chemical fume hood performance. The ANSI standards are excellent reference documents and provide relevant guidance for engineering control of hazards in the care and use of research animals. The following ANSI recommendations refer specifically to chemical fume hoods: â¢ A routine performance test should be conducted on every fume hood at least once a year or whenever a substantial change has been made in the opera- tional characteristics of the system. â¢ Each hood should maintain an average face velocity of 80-120 ft/min with no face-velocity measurement more than 20% greater or less than the average. â¢ New and remodeled hoods should be equipped with a flow-measuring device. Biological safety cabinets should be tested and certified after installation and whenever a stationary cabinet is moved and should be recertified at least once a year (CDC-NIH 1995). Performance certification criteria have been established by the National Sanitation Foundation (NSF 1992). Ultraviolet (UV) radiation of 254-nanometer (254-nm) wavelength may be used to control airborne and surface microorganisms in various locations in an animal care and research facility. The biocidal capacity of UV bulbs decreases with time and is adversely affected by contamination with dust or chemical films. They should be cleaned once a week and replaced on a regular schedule or monitored at least once a year to verify adequate performance (Fleming and others 1995, p.# 233). HEPA filtration units require periodic monitoring to ensure filtration effi- ciency (NSF 1992). Performance tests should be conducted at least once a year. Appropriate controls or decontamination should be used during replacement and certification because filters can become contaminated with potentially infectious agents, toxic chemicals, or radioisotopes during use. Charcoal filtration is occasionally used to control the environmental release of toxic materials or radionuclides. Performance is difficult to certify, and perfor- mance testing should be specific to the hazard that is being controlled (Shapiro 1990, p.# 331). Performance should be monitored either by using continuous monitoring instruments, which are calibrated to the chemicals of concern and placed downstream of the exhaust-filter bed, or by periodically sampling the discharge air. An acceptable alternative to monitoring charcoal filtering systems is to replace the filters at established intervals that are based on their calculated effective life. Ductless fume hoods that use mainly activated charcoal filters
118 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS should not be used for protection from volatile toxic compounds (Keimig and others 1991; NRC 1995, p.# 185). Ventilation system performance should be checked periodically to document adequacy of room air exchanges and air pressure gradients in accordance with authoritative guidelines (NRC 1996). Air pressure gradients indicate airflow rela- tionships; the frequency of monitoring them should be based on the degree of risk associated with the hazardous materials being used. Continuous readout monitor- ing instruments might be appropriate to provide instantaneous performance infor- mation in high containment facilities. Effluent monitoring might be required by local ordinances designed to pro- tect the sewage treatment works of the municipality. Specific, periodic monitor- ing might be required for ensuring compliance with discharge limits for chemi- cal, biological, or radiological agents. Additional monitoring could also be necessary to demonstrate adequate control after accidental spills or releases of materials that might have entered the sewage system. Validation and verification are important aspects of autoclave performance testing. The use of biological indicators that contain bacterial spores is an effec- tive method of validating sterilization cycles for various load types. Monitoring of autoclave operational measures (temperature, pressure, and time) can verify performance routinely. Fire protection systems and equipment (such as fire extinguishers) should be inspected and tested periodically to ensure operational integrity. Insurance com- panies and local fire authorities generally specify the frequency with which these inspections and tests should be performed. INFORMATION MANAGEMENT Rapid access to employee-specific exposure information is increasingly important for efficient safety management. Documentation of occupational expo- sures, safety training, medical surveillance, and work related injury and illness is important for evaluating the occupational health and safety program of the insti- tution, promoting health and safety, identifying new occupational risks, ensuring the cost effectiveness of program activities, and achieving regulatory compli- ance. On-line access to relevant health and safety information could improve the management and performance of occupational health and safety programs. It would facilitate the exchange of information between environmental health and safety, occupational health, animal care and use, and research staffs. On-line interactions could make it practical to develop records that are specific for each research protocol and that contain information relevant to each potentially ex- posed employee. Table 6-1 lists examples of information elements that can be shared in an occupational health and safety information-management network. Confidentiality and limited access to some kinds of information should be en- sured.
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 119 TABLE 6-1 Occupational Health and Safety Information-Management Network Information Provided Information Received Activity by Activity by Activity Animal care and use Job profile List of employees at risk Project risk data Employment risk indicators Training records Exposure and monitoring data Health evaluation data Health surveillance data Health surveillance schedules Material safety data sheets Risk assessment data Training schedules Research Job profile List of employees at risk Project risk data Employment risk indicators Training records Exposure and monitoring data Health evaluation data Health surveillance data Health surveillance schedules Material safety data sheets Risk assessment data Training schedules Environmental Accident and injury List of employees at risk health and safety investigation data Hazardous materials Employment risk indicators purchasing data Exposure and monitoring data Health evaluation data Material safety data sheets Health surveillance data Risk assessment data Job classification and position Training schedules descriptions Job profile OSHA 200 log data Project risk data Training records Worker compensation data Occupational health Health evaluation data Accident and injury Health surveillance information investigation data Health surveillance schedules List of employees at risk Employment risk indicators Exposure and monitoring data Job profile Material safety data sheets OSHA 200 log data Risk assessment data Worker compensation data continued on next page
120 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS TABLE 6-1 Continued Information Provided Information Received Activity by Activity by Activity Administration and List of employees at risk Accident and injury management Hazardous materials purchasing data investigation data Job classification and position Employment risk indicators descriptions Job profile OSHA 200 log data Project risk data Worker compensation data Computer links with other institutions through external networks, such as electronic mail, are useful for obtaining current health and safety information. Numerous safety bulletin boards are available for communicating with health and safety personnel throughout the world. Other specialty boards provide easy ac- cess to information regarding infectious, toxic, and radiological hazards. EMERGENCY PROCEDURES All institutions should have emergency response plans. Emergency situa- tions will occur, and they require a rapid, coordinated response to minimize harm to personnel and facilities. A rapid and appropriate response is not possible without an institutionally adopted written and tested plan. An emergency response plan provides a structure for effective response by defining employee responsibilities, interactions between responding personnel, the sequence of response procedures, and availability of emergency equipment. The complexity of the plan will be dictated by the diversity of emergencies that are considered possible and the institutional capacity and ability to respond to emergencies with on-site personnel. Environmental health and safety personnel should be readily available to coordinate response efforts, and all off-site emer- gency responders should be well educated in the unique hazards and situations that might occur. All on-site employees should know their roles in responding to emergency situations. The planning process should follow a logical progression that begins with identification of the types of emergency situations that are most likely to occur. That information is used to determine who should respond to each identified situation. Equipment requirements need to be determined by those who will respond to emergencies. After adoption of the written plan by the institution, training will need to be conducted and drills performed to test its efficacy. The emergency response team for an animal facility should either include or have rapid access to health and safety, veterinary, and animal care personnel. Hazards related to the animal care and use program should be known to ensure
PRINCIPAL ELEMENTS OF AN OCCUPATIONAL HEALTH AND SAFETY PROGRAM 121 that adequate equipment and training are available. All personnel involved in emergency response should know the limitations of their training and equipment and not perform activities for which they have not been trained. Typically, the hierarchy for response will be to protect personnel, then ani- mals, and finally the animal care facility and surrounding buildings. The plan should include provisions for moving or relocating animals to temporary housing facilities. The temporary facilities should be adequately equipped to address the needs of the different species that might require relocation. Medical personnel should receive specific information on the unique hazards related to emergency response procedures in the animal facility. They will need to be prepared to support the potential exposures and injuries related to emer- gency responses. All injuries managed by medical personnel should be included in the system for reporting work related injuries and illnesses. PROGRAM EVALUATION The quality and effectiveness of an institutionâs occupational health and safety program can be sustained only through periodic evaluations of the program and a commitment to respond to changing circumstances. Evaluations should be performed at the request of the senior official of the institution, who should act on the findings. The source of the request establishes institutionwide interest in the evaluations, involves top administration in the deliberations, and ensures close communication between the evaluation group and institutional officers. Members of the evaluation group should be appointed by the senior official of the institution. The group should include appointees from each of the major activities in the occupational health and safety program. Individually, the mem- bers should be recognized by their peers as persons of good judgment. All should have a personal commitment to the objectives of the occupational health and safety program. Chairpersons of relevant committees should participate in the evaluation, and the managers of the environmental health and safety and occupa- tional health activities should serve as resources for the group. The evaluation should be based on objective data that will help in measuring the effectiveness of the program in reducing occupational risks to an acceptable minimum. Three general subjects should be emphasized: the institutionâs injury and illness experience, its regulatory-compliance performance, and the results of efforts to promote health and safety through continuing interactions among the major participants in the occupational health and safety program. The data sources should include the results of exposure monitoring if per- formed for any purpose, worker compensation records, OSHA recordable inju- ries and illnesses, results of special health and safety studies or investigations, training records, minutes and reports of institutional health and safety committees and any related actions taken by the IACUC, and results of inspections conducted by regulatory agencies. Some institutions perform self-audits to identify deficien-
122 OCCUPATIONAL HEALTH AND SAFETY OF RESEARCH-ANIMAL WORKERS cies or recommend improvements in their environmental, health, and safety regu- latory-compliance activities; this approach is viewed favorably by most regula- tory agencies. The best measure of the effectiveness of interactions among the major par- ticipants in the program is whether the health and safety policies, rules, and recommended practices are relevant to the hazards that are present and can be implemented in a practical manner. That might well be a subjective assessment, but it is exceedingly important. Relevance and practicability influence attitudes, and positive attitudes toward the occupational health and safety program mini- mize risks.