Centers for Disease Control and Prevention (CDC) workers were potentially exposed to live anthrax between June 5 and June 13, 2014. Sixty-two workers were provided or prescribed antibiotics after the exposure was discovered.
Environmental remediation involves clean-up of hazardous materials, many of which are toxic heavy metals regulated by OSHA such as arsenic, beryllium, cadmium, hexavalent chromium, lead and mercury. Medical screening and surveillance are addressed in OSHA standards on asbestos, inorganic arsenic, lead, cadium, benzene, and methylenedianiline (MDA), as well as other hazardous materials.
Workers required to wear respirators against these exposures must be medically evaluated according to OSHA’s respiratory standard to determine their fitness for using a respirator. In addition, employers must institute a medical surveillance program for all employees who are, or may be exposed to levels of heavy metals such as cadmium, arsenic and lead at or above the action level for 30 or more days per year.
In addition, OSHA’s standard for Hazardous Waste Operations and Emergency Response (HAZWOPER) requires that a written health and safety program (HASP) include a detailed program for monitoring the general health of workers who are potentially exposed to hazardous substances in the field and who wear respirators 30 days or more per year. The program must include baseline or pre-assignment monitoring, periodic monitoring, site-specific medical monitoring, exposure/injury/medical support, and an exit physical.
Employers should be aware of loopholes or shortcomings of medical surveillance programs uncovered by the EPA in the 1990s. Under HAZWOPER, workers who do not meet OSHA’s 30-day trigger are not required to be offered periodic medical surveillance evaluations. Some consider the 30-day trigger an invitation to hire short-term workers to perform the dirtiest and more dangerous jobs without incurring the costs of medical supervision. Representatives from some national environmental firms told the U.S. Office of Technology Assessment (OTA) that they believed failure to include all employees on a hazardous waste site in surveillance programs amounted to negligence and an invitation to litigation in the event of a worker injury or illness.
Guidelines for medical surveillance programs covering EPA employees concede that brief, high-dose exposure to toxins may carry as much risk, and sometimes greater, risk than longer but lower dose exposures. Likewise, some exposures, work tasks and work conditions might be more hazardous than others. But HAZWOPER does not link mandated medical surveillance to such considerations.
Because the precise hazards and nature of possible worker health impacts associated with hazardous waste operations are poorly understood, it is important to use medical surveillance results to take advantage of every opportunity to practice primary prevention. Unless surveillance data are translated into improved work site health and safety practices, screening and monitoring… become “sound and fury, preventing nothing,” according to Dr. Michael Silverstein, in “Medical Screening, Surveillance and the Prevention of Occupational Disease,” published in the Journal of Occupational Medicine.
“Sound and fury, preventing nothing” points to the importance of partnering with a medical screening and surveillance provider with a roster of clients involved in environmental remediation or whose clients face general exposures to dangerous chemicals. Experienced providers with nurses and physicians board certified in occupational medicine on staff can “plug the gaps” in medical surveillance programs, go beyond compliance minimums to offer preventive medicine and help avoid potential litigation.