#18,361
Roughly a month ago the CDC released Updated (Sept 27th) Information for Workers Exposed to H5N1 Bird Flu, along with more detailed guidance for their Employers. As we discussed then, the CDC can only make recommendations and has no legal authority to force compliance to these measures.
Which explains why the word `should' appears 40 times in today's updated guidance document, while the word `shall' (indicating a requirement) does not appear even once.
Based on media reporting (see STAT news Farmers resist push for workers to wear protective gear against bird flu virus), many of their earlier recommendations have gone unheeded.
Yesterday the CDC released updated Interim Guidance for Employers, which `. . . identifies select occupational groups that may be at increased risk of exposure to novel influenza A viruses associated with severe disease in humans and clarifies previous recommendations.'
This is a lengthy, detailed, and important update - but whether it is taken seriously, and adopted by employers remains to be seen.
The link to, and a brief except from the guidance follows, but I urge you to read it in its entirety.
OCTOBER 23, 2024
Interim Guidance for Employers to Reduce the Risk of Novel Influenza A for People Working with or Exposed to Animals
A brief excerpt follows.
Employers should take steps to reduce workers' risk of infection with novel influenza A viruses from sick animals or contaminated environments. Workers may be at risk when working with animals confirmed or potentially infected with novel influenza A viruses or working with materials, including raw milk, that are confirmed or potentially contaminated with novel influenza A viruses. Examples of related workers include:
- Poultry and dairy and other livestock farmers and workers
- Backyard bird flock owners
- Veterinarians and veterinary staff
- Animal health responders
- Public health responders
- Dairy laboratory workers
- Food processing workers handling raw milk and other confirmed or potentially contaminated materials
- Slaughterhouse workers performing certain tasks on lactating dairy cattle including:
- Unloading or handling live lactating dairy cattle for slaughter, including working in holding pens and tasks involved with ante-mortem inspection
- Post-mortem processes including the post-mortem inspection, handling, and transporting of viscera
- Removing and transporting udders from dairy cattle for further processing or rendering
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.
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.
