#18,323
In May, the CDC released Recommendations On Making PPE Available To Workers on Dairy Farms, Poultry Farms, and in Slaughterhouses.
Even though the number of infected farm workers has grown (n=13) over the summer, the CDC has no legal authority to enforce compliance with these measures, and we've seen considerable resistance from farmers (see STAT news Farmers resist push for workers to wear protective gear against bird flu virus).
Admittedly, the recommended PPE can be unbearably hot (particularly during the summer months), can restrict movement and communication (both safety issues), and can be difficult to properly don and doff.
While it involves some significant compromises, earlier this month the Journal of Infectious Diseases published an article calling for PPE against HPAI H5N1 to Be Adapted to Meet the Needs of Dairy Farm Workers.
On Friday (Sept 27th) the CDC published updated guidance for farm workers (below) - and more detailed guidance for their Employers - including several new graphics.
I only reproduced some excerpts from a much longer guidance document (which includes donning & doffing procedures), so follow the link to read it it is entirety.
I'll have more after the break.
Information for Workers Exposed to H5N1 Bird Flu
AT A GLANCE
H5N1 bird flu is a virus that has recently been detected for the first time in cows and can be found in poultry and other animals. The virus can infect people who work with infected animals or their byproducts (for example, raw milk), such as dairy and poultry workers. Your employer should develop a workplace health and safety plan and share it with you. This page was updated to include more details about using personal protective equipment safely.
Overview
Information for employers
CDC has created guidance to help your employer.
Reducing Risk for People Working with or Exposed to Animals
This H5N1 bird flu virus has been found at high levels in the milk of infected dairy cows. It has also been found in the lungs, muscle, and udder tissue of infected dairy cows. This virus has been spreading among dairy cows in multiple U.S. states and has also been found in poultry flocks. It is widespread in wild birds and has been found in some mammals, including cats. Symptoms in animals vary, with high death rates in poultry but often mild symptoms in cows, including coughing, sneezing, runny eyes or nose, or lack of appetite.
Although H5N1 bird flu usually does not infect people, there have been some infrequent cases of human infection. Confirmed cases detected in the United States to date have all been mild. However, symptoms in people can range from no or mild to severe, including death. If you work with animals or materials that could be infected or contaminated with H5N1 bird flu, you can take steps to reduce your risk of getting sick. Consult your supervisor or your employer's health and safety committee to determine how best to apply these recommendations.
(SNIP)
Wear PPE
Wear PPE when in contact with or around dairy cows, raw milk, other animals, or surfaces and other items that might be contaminated. You may need more PPE than what you use for your normal duties. Your employer should provide the recommended PPE at no cost. Ask your supervisor if you have questions about what type of PPE to wear or when or how to use it. Putting on and removing PPE should occur during work hours.
(SNIP)
While wearing PPE
- Avoid touching yourself above your chest, especially your eyes, mouth, or nose, after touching any contaminated material
- Do not eat, drink, touch your phone, smoke, vape, chew gum, dip tobacco, or use the bathroom
- Work in pairs and pay closer attention to your surroundings for hazards such as animal movement
- Protect yourself from heat stress
- Learn the symptoms and risk factors, first aid, and prevention for heat-related illness.
- Work with a buddy and observe each other for signs of heat-related illness.
- Take frequent breaks to rest and hydrate in a cool clean area after removing dirty PPE. This is important because removing PPE to take a drink while you are still working could exposure you to virus that could make you sick.
- Stay hydrated and avoid alcohol and drinks with high caffeine or sugar.
- Understand how certain medicines may increase the risk of heat-related injury and talk to a healthcare worker for help.
(SNIP)
Know your rights
Federal law entitles you to a safe workplace. Your employer must keep your workplace free of known health and safety hazards. You have the right to speak up about hazards without fear of retaliation. See the Occupational Safety and Health Administration's Worker Rights and Protections page or more information
I expect some of these recommendations (e.g. Do not eat, drink, touch your phone, smoke, vape, chew gum, dip tobacco, or use the bathroom while wearing PPEs) are going to be a hard sell to employees, assuming employers are willing to implement these measures.
The updated guidance for Employers is much longer, and far more detailed, although it is worth noting that the word `should' appears 40 times (see brief excerpt below), which generally indicates a recommendation, not a requirement.
To protect workers who might be exposed, employers should update or develop a workplace health and safety plan. Employers are encouraged to use a health and safety committee that includes representatives from both management and workers to develop the plan. Helpful guidance and consultation on developing a workplace health and safety plan is available from the Occupational Safety and Health Administration (OSHA) and through your local agriculture extension office. Employers should conduct a site-specific hazard assessment to identify potential exposures based on job tasks and locations and use the hierarchy of controls to identify controls to reduce or eliminate hazards including exposure to novel influenza A viruses. The Hazard Assessment Worksheet for Dairy Facilities can help identify dairy workplace hazards and prioritize controls including PPE needed for protection. Protecting Poultry Workers from Avian Influenza (Bird Flu) can help identify poultry workplace hazards and prioritize controls.
Employers should ensure workers are protected from being exposed to the virus if workers have direct or close physical contact with:
- Any animals that are confirmed or potentially infected, including birds, dairy cows, and other livestock
- Feces, urine, or litter from these animals
- Raw (unpasteurized) milk from these animals
- Any animals that have died, including birds and livestock
- Viscera or udders from lactating dairy cattle
- Surfaces and water (for example, ponds, waterers, buckets, pans, troughs) on farms with potentially infected animals that might be contaminated with animal waste or waste milk
While the CDC cites OHSA regulations, there are no HPAI H5N1 specific rules on the books. From the OSHA site:
There is no specific OSHA standard covering avian influenza viruses; however, the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), which 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" may be cited where uncontrolled occupational hazards are present and no other OSHA standard is applicable to address those hazards.
People who work in operations 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 H5N1 exposure and illness.
I'll leave the finer legal distinctions between `should' and `must', and what constitutes a `. . . place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm', to the lawyers and the courts.
While it is important to have the `best practices' laid out by the CDC, for now it still appears largely up to the individual farm owner and/or operator whether, or to what extent, they are willing to follow these recommendations.
And so far, they haven't shown much enthusiasm in doing so.
