Employers should know the facts about avian influenza, such as risks, transmission, and symptoms, and how to use personal protective equipment with OSHA’s resources to prevent those who work with animals from catching it. Employers of operations that work with poultry (including eradication of sick birds), cattle and other livestock (dairy, meatpacking, etc.) and their byproducts (viscera, raw milk, etc.) should take extra precautions to reduce the risk of bird flu exposure and illness. While rare, workers can be infected through unprotected exposure to infected birds or animals through inhaling, or touching an infected animal and then touching their eyes, nose, or mouth. Employers should take extra precautions to avoid worker unprotected exposure to dead animals/birds, animal waste, bedding, raw milk/uncooked animal products, or materials touched by, or close to animals with suspected or confirmed avian influenza. Workers who have no gloves or other personal protective equipment with infected animals or their products are at risk of infection.
Relevant OSHA Standards
While there is no OSHA standard specifically, for avian influenza, employers should be aware of other relevant sections. The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1) requires employers to give 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.” Employers should be wary that this section may be cited where uncontrolled occupational hazards are present and no other OSHA standard is applicable.
Other standards are likely applicable as well. 29 CFR 1910 Subpart I lays out requirements of OSHA’s PPE standards for the use of gloves, eye and face protection, and respiratory protection. 29 CFR 1910 Subpart J provides standards for sanitation in the workplace. 29 CFR 1910 Subpart Z may be applicable if workers are exposed to human blood or other potentially infectious, the Bloodborne Pathogen Standard. 29 CFR 1910 Subpart K may also be applicable, which deals with medical services and first aid. Employers should know these standards so you can be prepared if the bird flu does impact your workplace.
Conducting a Hazard Analysis
In preventing and controlling worker expose to avian influenza, employers should first conduct a hazard analysis to identify at risk workers, and institute changes as needed if such a risk is found. Changes could include different PPE, additional training for workers, and cleaning and disinfecting worksites.