1. What types of gloves are recommended as a precaution for anthrax exposure?
   
   Nitrile or vinyl gloves will protect workers from cutaneous anthrax exposure. Latex gloves offer protection similar to nitrile or vinyl gloves, but can result in sensitization or elicit allergic reactions in a small percentage of people. Since mail handling includes a range of tasks and is conducted in various occupational settings, gloves should be provided in a range of sizes and types to fit a variety of workers and job tasks. Employers whose employees work in situations where a gloved hand presents a hazard (e.g., work close to moving machine parts), can minimize risk by ensuring employee training on work practices, proper machine guarding, and correct fit of workers' gloves.
   
   OSHA's recommendations for assessing workplace risk and determining prudent work practices and personal protective equipment (PPE) are addressed in OSHA's Anthrax in the Workplace Risk Reduction Matrix. Please be aware that OSHA's standards for general PPE cover glove selection and use (29 CFR 1910.132) as well as hand protection (29 CFR 1910.138).
   
   Note: The US Postal Service (USPS), which continues to work closely with the Centers for Disease Control and Prevention (CDC) regarding the control of anthrax in its facilities [Update: Investigation of Bioterrorism-Related Anthrax and Interim Guidelines for Exposure Management and Antimicrobial Therapy. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality Weekly Report (MMWR) 50(42);909-919, (2001, October 26)], has purchased vinyl and nitrile gloves for postal employee protection (USPS News Release Oct 25, 2001).
   
   
2. What personal protective equipment would provide effective protection while handling mail if exposure to anthrax spores is a concern? Would this include respirators?
   
   OSHA's recommendations for assessing workplace risk, prudent work practices, and personal protective equipment (PPE) are addressed in the Anthrax in the Workplace Risk Reduction Matrix.
   
   Because the majority of recent cases of confirmed occupational anthrax contamination and infection have been related to mail delivered through the USPS, selecting appropriate personal protective equipment (PPE) depends on the amount of mail a worker handles, how he or she handles the mail, and where he or she works. Some factors to consider include: the current patterns of anthrax spore contamination; the nature of the workplace and amount of mail received; whether the facility receives mail directly from a USPS facility that is known to be contaminated with anthrax; and whether the facility uses equipment that might disperse dust or anthrax spores into the air. Employers also should consider factors such as information from law enforcement agencies in assessing employee risk.
   
   For the most part, employers whose workers handle small volumes of mail will not need to do more than to establish handling and screening procedures for mail. These employers may consider providing their employees with vinyl or nitrile gloves.
   
   Workers in USPS facilities often handle an extremely high volume of mail and may work around mail sorting equipment that could disperse anthrax spores contained in processed mail. As a result, the workers in these facilities may be at a higher risk of exposure than workers who handle smaller volumes of mail, and higher levels of PPE may be appropriate.
   
   As explained, OSHA does not recommend respirators for the vast majority of workers. If workers request respirators, however, and employers provide filtering facepiece respirators for voluntary use by employees, the employers must make sure that employees are provided with the information contained in Appendix D to OSHA's Standard for Respiratory Protection, 29 CFR 1910.134 ("Information for Employees Using Respirators When Not Required Under the Standard").
   
   To provide effective protection from anthrax spores, the CDC recommends the use of NIOSH-approved respirators that are at least as protective as an N95 respirator. In addition, persons working in areas where oil mist from machinery is present should use respirators equipped with P-type filters (P95 or P100) to prevent the oil mist from degrading the filter.
   
   At worksites where employers require workers to wear respirators, a respiratory-protection program that complies with the provisions of 29 CFR 1910.134 must be implemented. This includes compliance with the standard's requirements for obtaining medical clearance for wearing the respirator and for conducting fit testing before requiring their employees to use respirators. These latter requirements also apply to voluntary use of respirators that are not filtering facepiece respirators.
   
   
3. What precautions should healthcare workers (HCWs) take when treating patients who may be infected and/or contaminated with anthrax ( Bacillus anthracis)?
   
   Healthcare workers should use Universal Precautions for all patient care activities. "Universal Precautions" are standard approaches to infection control designed to reduce the risk of transmitting microorganisms from both known and unknown sources of infection. Universal Precautions can include, but are not limited to, appropriate use of gloves, masks, protective clothing, work practices, and housekeeping.
   
   Clinical anthrax illness occurs days or weeks after exposure to the anthrax spores and person-to-person spread of this disease has not been documented. Therefore, after the onset of clinical illness, no precautions specific to anthrax have been recommended.
   
   However, if healthcare workers are providing initial care to a patient with suspected recent exposure to anthrax, they should take precautions against the potential for reaerosolizing any anthrax spores remaining on the exposed individual or clothing. Further direction for appropriate personal protective equipment is available on OSHA's Anthrax in the Workplace Risk Reduction Matrix.
   
   
4. How should contaminated PPE used to handle mail (e.g. gloves) be disposed of? Can it go in regular trash?
   
   Unless the PPE has been used to handle a suspicious piece of mail, gloves and other personal protective clothing and equipment can be discarded in regular trash once removed. If a worker recognizes and handles a suspicious piece of mail, the worker's protective gear should be treated as potentially contaminated; it should be placed in an appropriately labeled and/or color-coded container that is closable and leak-proof. This container should then be disposed of as infectious/regulated waste.
   
   
5. What are the health and safety precautions for laboratory workers handling anthrax samples?
   
   The Centers for Disease Control and Prevention (CDC) has published advice for laboratory personnel. [Update: Investigation of Anthrax Associated with Intentional Exposure and Interim Public Health Guidelines, October 2001. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality (MMWR) 50(41);889-893, (2001, October 19)]. Lab personnel are advised to:
   
   
   • Use Biological Safety Level 2 facilities and practices (BSL-2 laboratories are suitable for work involving agents of moderate potential hazards) or Biological Safety Level 3 facilities and practices (BSL-3 laboratories are suitable for work involving indigenous or exotic agents that have a potential for respiratory transmission and may cause serious or potentially lethal disease) when working with clinical samples considered potentially infectious;
   • Wear protective eyewear (e.g., safety glasses or eye shields) and handle all specimens in a BSL-2 laminar flow hood, use closed-front laboratory coats with cuffed sleeves, and stretch gloves over the cuffed sleeves;
   • Avoid any activity that places them at risk for infectious exposure, especially activities that might create aerosols or disperse droplets;
   • Decontaminate laboratory benches after each use and dispose of supplies and equipment in proper receptacles;
   • Avoid touching mucosal surfaces with hands (gloved or ungloved), and never eat or drink in the laboratory; and
   • Remove and reverse gloves before leaving the laboratory, dispose of them in a biohazard container, remove laboratory coat, and wash hands.
   
   For additional information, see Protocols: Interim Recommended Notification Procedures for Local and State Public Health Department Leaders in the Event of a Bioterrorist Incident. Centers for Disease Control and Prevention (CDC), (Reviewed May 11, 2005).
   
   
6. What respirators are recommended for protection against smallpox?
   
   Unlike anthrax, which is acquired only from direct exposure to anthrax spores, smallpox is a highly contagious disease, often spread from person to person. No general workplace guidance exists regarding respiratory protection for smallpox.
   
   For laboratory work, current recommendations require BSL-4 facilities and practices (laboratories suitable for work with dangerous and exotic agents posing high individual risk of laboratory infections and life-threatening disease) for laboratory personnel. Other recommendations are not available, however the CDC offers additional information regarding the smallpox vaccination.
   

7. What personal protective equipment is recommended for emergency responders in the event of a suspected anthrax threat?
   
   The type of personal protective equipment (PPE) needed for effective protection depends on different response situations, what is known or unknown about the situation, and the potential risk. Please be aware that emergency response to an anthrax spore release is covered by the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), so the PPE that is selected and used must be consistent with the standard. The standard is performance-oriented and requires the selection and use of PPE to be proportional to the anticipated risk of exposure and appropriate to the nature of the anticipated hazard.
   
   Recent releases and contamination have generally been associated with mail sent through the US Postal Service (USPS). When mail-handling equipment has already been locked and tagged out, thus providing a reliable assurance that anthrax will not be reaerosolized due to equipment start-up or operation, workers responding to these types of releases have worn modified Level C protection with a full-face tight-fitting Powered Air Purifying Respirator (PAPR). However, activities which may result in spore release, such as removal of a suspect contaminated mail item, or after releases where the agent or method of disbursal is unknown, and/or the release is ongoing will require higher levels of protection.
   
   OSHA's recommendations concerning prudent work practices and PPE for emergency responders are addressed in Anthrax in the Workplace Risk Reduction Matrix.
   
   
8. For those security personnel who may be asked to secure a room or area because of potential contamination:
   
   What personal protective equipment should be supplied and worn? What should such personnel do to prevent access to that area or prevent exposed persons from leaving the area?
   
   If an exposure to anthrax spores is suspected, proper emergency response protocols should be followed. Individuals not specifically trained to handle situations involving anthrax should not be in or near the potentially contaminated area. Emergency responders should secure affected areas.
   
   If security personnel secure the area they are considered emergency responders. Depending on the tasks that they are likely to perform, these individuals may be first responders at either the "awareness" or "operations" level. See the answers to Questions 1 and 2 for information regarding the use of appropriate personal protective equipment.
   
   Security personnel who will not take any actions other than to cordon off the affected area and/or initiate the emergency response sequence are considered "first responders at the awareness level." Security personnel who are required to close doors, physically isolate the area, or take any other defensive action are considered "first responders at the operations level."
   
   For additional information about emergency responders and training levels, please refer to Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases. OSHA Directive CPL 02-02-073, (2007, August 27). Also available as a 444 KB PDF, 119 pages. Updates enforcement procedures for compliance officers who need to conduct inspections of emergency response operations. It defines additional terms and expands on training requirements for emergency responders and other groups such as skilled support personnel. This OSHA instruction revises CPL 02-02-059, issued April 24, 1998.
   

Mail-Related Work Practices

9. It is standard procedure for the post office employees to use compressed air to clean the mail processing machines (address/zip code reader optics). Is this acceptable? If not, what cleaning method is acceptable?
   
   The US Postal Service has banned the use of compressed air ("blowout") as a method of machine maintenance because compressed air has a high risk potential for aerosolizing anthrax spores.
   
   Other employers should also avoid practices like dry sweeping and blowing off machinery with compressed air; instead employers should use wet-clean, mop, or vacuum methods. When vacuuming mail handling and sorting equipment is chosen, an industrial vacuum that is equipped with a High Efficiency Particulate Air (HEPA) filter should be used. Do not use a standard industrial vacuum or a "HEPA" equipped home-style vacuum.
   
   Additionally, proper procedures and work practices should be followed during maintenance of machinery in order to protect workers from other potential injuries.
   
10. Should mail-handling facilities take air and/or surface samples for traces of anthrax?
    
    No. Routine sampling is not recommended, unless an employer has a reason to suspect that anthrax contamination has occurred. If there is a suspected exposure or contamination, established emergency response procedures must be followed.
    
    
11. What is the safest way to handle individual letters or packages?
    
    
    • Be on the lookout for suspicious envelopes or packages.
    • DO NOT open suspicious mail.
    • Open all mail with a letter opener or other method that minimizes skin contact with the mail and is least likely to disturb contents.
    • Open mail with a minimum amount of movement.
    • Do not blow into envelopes.
    • Do not shake or pour out contents.
    • Keep hands away from nose and mouth while working with and opening mail.
    • While opening mail, turn off fans, portable heaters, and other equipment that may create air currents.
    • Wash hands thoroughly with soap and water after handling mail.
    • More information is available in OSHA's Workplace Response to Anthrax Threat: OSHA Recommendations for Handling Mail.
12. What do I do if I come across a suspicious piece of mail?
    
    
    • Do NOT open the package or letter.
    • Do not shake, empty, or otherwise disturb its contents.
    • Put the package down and do not handle it further.
    • Do not touch or try to clean up the substance.
    • Alert others nearby.
    • Do not remove ANY items from area.
    • Leave the area and gently close the door.
    • Wash hands well with soap and water.
    • Contact your supervisor, designated responder or other appropriate authority.
    • Limit movements within the building to prevent spread of substance.

13. Is an employer obligated to pay for pre-exposure anthrax tests (i.e. blood, titer, etc.)?
    
    Employers are not legally required to offer or pay for anthrax exposure tests. Employees may wish to contact the Centers for Disease Control and Prevention (CDC) to obtain information about low-cost or no-cost testing and treatment at (404) 639-3534.
    
    
14. Should I visit my doctor if I have a fever, congestion, or flu-like symptoms?
    
    If you have not been present in an area where there is a potential for exposure to anthrax spores, the chance of anthrax infection is remote, and antibiotic therapy is usually not indicated. Anthrax is not spread by person-to-person contact. Therefore, there are no recommendations to immunize or treat contacts of persons with clinical anthrax illness, such as household contacts, friends, or coworkers, unless they were also exposed to the same source of infection.
    
    The CDC recommends the anthrax vaccine for employees working in laboratories involved in testing for anthrax, workers who decontaminate sites known to be contaminated with anthrax, and workers who typically work in areas with high naturally occurring concentrations of anthrax (e.g., wool-sorters).
    
    Further information can be obtained on-line at the CDC's Emergency Preparedness & Response; or CDC's newly established toll-free CDC Public Response Hotline. For English, call (888) 246-2675; por Español, llame al (888) 246-2857.
    
    
15. Should I get an anthrax vaccination?
    
    At this time, vaccination against anthrax for the general public to prevent disease is not recommended. Further information can be obtained on-line at the CDC's Anthrax: Vaccination.
    
    
16. Should I start taking preventive antibiotics?
    
    The CDC strongly recommends against the use of preventive antibiotics for the general population. Unless there is strong or compelling evidence to suggest that you may have been exposed to anthrax, you should not take preventive antibiotics. However, if you are concerned, you should discuss this with your healthcare provider.
    
    
17. What types of businesses would be expected to prepare for terrorist attacks?
    
    Terrorist activity is unpredictable, though current anthrax contamination has been primarily isolated to mail handling facilities. For more information regarding potential anthrax exposures in a workplace, refer to OSHA's Anthrax in the Workplace Risk Reduction Matrix.

18. Since the anthrax hazard is an emergency/unexpected hazard, will OSHA waive the requirements for medical evaluations (medical questionnaire and examinations) for employees required to wear respiratory protection and employees who voluntarily use such protection?
    
    In worksites where respiratory protection is required to be worn, a respiratory protection program that complies with the provisions of OSHA's Respiratory Protection Standard, 29 CFR 1910.134, must be implemented, including medical examinations as indicated. Medical evaluations are not required for employees who are wearing filtering facepiece respirators on a voluntary basis.
    
    
19. Does 29 CFR 1910.120 (HAZWOPER) apply to initial responders for anthrax releases?
    
    Yes. The release of anthrax spores into a workplace as an act of terrorism is an emergency situation. Compliance with Hazardous Waste Operations and Emergency Response, 29 CFR 1910.120, is required for emergency response personnel responding to a possible anthrax release. (See response to Question #7, above.)
    
    
20. Does OSHA have a protocol for testing for anthrax?
    
    No. OSHA does not analyze samples for the presence of anthrax spores. A list of qualified laboratories and laboratory procedures can be found on OSHA's webpage.
    
    
21. If I require my employees to wear respirators for potential anthrax exposure, what must I do to ensure that I am in compliance with OSHA's Respiratory Protection standard?
    
    Required use of respirators triggers the requirements under 29 CFR 1910.134, OSHA's Respiratory Protection standard. Guidance on complying with OSHA's standard can be found in Inspection Procedures for the Respiratory  Protection Standard, CPL 02-00-120 [CPL 2-0.120].

22. How will OSHA offices handle the cases involving the hospitalization of three or more employees (catastrophe) due to anthrax or other biohazard exposure?
    
    OSHA offices will handle a catastrophe or fatality caused by exposure to anthrax spores or other biohazards like any other fatality or catastrophe. OSHA requires an employer to report the incident to OSHA within eight hours of an employee's death or the hospitalization of three or more employees.
    
    
23. How will OSHA offices handle safety and health complaints from USPS workers and other workers who handle mail regarding:
    
    A. Provision or lack of provision of PPE or vaccinations/titers?
    B. Cleaning mail equipment with compressed air?
    C. Possible, but unproven, exposure to anthrax?
    
    To date, OSHA has handled safety and health complaints received from the USPS through established phone and fax procedures. Complaints received from other employees working in mail handling operations will be conducted in a similar fashion. The callers should also be made aware of the information on workplace anthrax exposures, which is available on and through OSHA's website.
    
    
    • See response to Question #1 and Question #2 regarding the provision of gloves and respiratory protection. With regard to the provision of vaccinations or titers for anthrax exposure, vaccinations are neither required nor routinely recommended for mail handlers.
      
      
    • The USPS no longer sanctions the use of compressed air to clean equipment; all equipment is cleaned using HEPA-filtered vacuums. (See response to Question #9, above.)
      
      
    • When an Area Office or OSHA Consultation Office receives an employer request for OSHA to "sample for possible workplace exposure to anthrax," the employer should first be queried about the steps he or she has taken to ascertain whether there is a credible threat of exposure to anthrax. OSHA will then explain that it does not conduct analyses for anthrax samples, and employers should be encouraged to contact outside private firms in order to determine whether there is anthrax contamination in the workplace.
      
      
24. How will OSHA handle safety and health complaints alleging exposure to anthrax?
    
    Any complaint alleging a workplace hazard requires basic inquiry to determine whether any evidence of a hazard exists. If a complainant alleges an immediate exposure to anthrax, the employer or employer's representative must notify the proper emergency response personnel. If the complainant is concerned about PPE or exposure to anthrax spores, but no immediate exposure has been alleged, the complaint will be handled as an informal complaint.
    
    
25. Does OSHA require licensed professionals to monitor the workplace for anthrax?
    
    No. OSHA does not require monitoring; thus OSHA does not have licensing requirements for professionals who monitor for anthrax.

26. If an employee dies or is injured or infected as a result of terrorist attacks, should it be recorded on the OSHA Injury and Illness Log? Should it be reported to OSHA?
    
    Yes, injuries and illnesses that result from a terrorist event or exposure in the work environment are considered work-related for OSHA recordkeeping purposes. OSHA does not provide an exclusion for violence-related injury and illness cases, including injuries and illnesses resulting from terrorist attacks.
    
    Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, an employer must orally report the fatality/multiple hospitalization by telephone or in person to the OSHA Area that is nearest to the site of the incident. An employer may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).
    
    
27. An employee is provided antibiotics for anthrax, although the employee does not test positive for exposure/infection. Is this a recordable event on the OSHA log?
    
    No. A case must involve a death, injury, or illness to be recordable. A case involving an employee who does not test positive for exposure/infection would not be recordable because the employee is not injured or ill.
    
    
28. An employee tests positive for anthrax exposure/infection and is provided antibiotics. Is this a recordable event on the OSHA log?
    
    Yes. Under the most recent Recordkeeping requirements, which will be effective in January 2002, a work-related anthrax exposure/infection coupled with administration of antibiotics or other medical treatment must be recorded on the log. Until the new Recordkeeping requirements become effective, an employer is required to record a work-related illness, regardless of whether medical care is provided in connection with the illness.

29. Do Occupational Safety and Health (OSH) Act Whistleblower provisions apply to employees who believe that they are being discriminated against because of their beliefs, fears, or occupational risks?
    
    Whistleblower provisions protect employees against employer retaliation for having exercised certain "rights" detailed in the OSH Act and its implementing regulations (29 CFR 1977). Among those rights are the right to file a formal complaint regarding safety and health conditions with OSHA; notify or complain to management about unsafe or unhealthful working conditions; and, in limited circumstances, refuse to perform a task that exposes the employee to a real danger of death or serious physical harm (See Question #30, below, for more information regarding work refusals). Employers or other persons are prohibited from discharging or taking other adverse personnel actions against an employee in retaliation for the employee's involvement in a protected activity. Employees who feel they have been discriminated against in violation of Section 11(c) may file a complaint with the local OSHA Area Office.
    
    
30. Can I refuse to go to work in a facility where anthrax is known to be present and will I be covered under 11(c) of the Occupational Safety and Health Act (the Act)?
    
    The regulations and court decisions interpreting the OSH Act provide that employees do not have an absolute right to "walk off the job" because of potential unsafe working conditions. However, occasions might arise when an employee is confronted with a choice between refusing to perform an assigned task and subjecting him or herself to serious injury or death arising from a hazardous condition at the work place. If the employee chooses to not perform the assigned task, the situation must meet four specific criteria in order to qualify for protection under Section 11(c) of the OSHA Act:
    
    
    • The condition must be such that a reasonable person would conclude that there is a real danger of death or serious physical harm,
      
      
    • There is no reasonable alternative way of performing the work,
      
      
    • The employee must have sought and been unable to obtain correction of the hazard from the employer, AND
      
      
    • There is insufficient time to eliminate the danger through resort to regular statutory enforcement channels (e.g., calling OSHA).
      
    
    More information is available on OSHA's Worker's Page.