OSHA takes center stage in anthrax war by putting risks in perspective

Matrix helps assess chance of worksite contamination

In the continuing saga of "the problem that won’t quite go away," the Occupational Safety and Health Administration (OSHA) in Washington, DC, has stepped forward with a new tool for helping occupational health professionals assess the risk of anthrax contamination in the workplace. Called the Anthrax Matrix, in OSHA’s words, it "guides employers in assessing the risk to their workers, providing appropriate protective equipment, and specifying safe work practices for low-, medium-, and high-risk levels in the workplace."

One of the key goals of the matrix is to put the risk of contamination into perspective. As U.S. Labor Secretary Elaine L. Chao pointed out when announcing the Matrix, there have been only five deaths and 17 confirmed cases of anthrax infection. Nevertheless, as this issue went to press, the U.S. Department of Health and Human Services announced it would make the anthrax vaccine available to congressional employees and others deemed at risk.

The bottom line is folks are still worried. "We were getting a tremendous number of questions — not only from the post office or [the Department of] Justice, but from private employers and employees," notes Richard Fairfax, CIH, OSHA’s director of compliance programs. "Do they need to be worried? How can they assess their workplace and determine the level of risk? What precautions should they be taking? Based on these calls, John Henshaw, assistant secretary for the Department of Labor, decided OSHA needed to come out with something to answer those questions."

"The problem is everybody’s so hysterical about it," adds Iris Udasin, MD, associate professor and medical director of environmental and community medicine at the University of Medicine and Dentistry of New Jersey Medical School in Piscataway. "I’m involved with a lot of post offices, and some people there are burning their mail, torturing’ their mail. I think the situation became unsettling because of the people who acquired anthrax with what I would consider a minimal amount of exposure, so of course it’s scary, but by the same token there aren’t that many people who have the illness."

Udasin is also pleased to see OSHA take such a high-profile position in the anthrax war. "Occupational health people were not involved early on," she notes. "We needed to stand up and be counted. People still look to the [Centers for Disease Control and Prevention] CDC, which is fine, but they are not occupational health people; it’s good we’re working together."

Part of OSHA’s rationale for the matrix, says Fairfax, was to create a single resource after discussions with other government agencies, such as the CDC. "We certainly didn’t want to contradict what had been written before," he notes, "but we also wanted to write to a different audience than the CDC. We wanted it to be in more understandable language for a wider range of people."

Making informed decisions

OSHA’s anthrax matrix, which can be found on its web site at www.osha.gov, has several components, including a section on assessing risk entitled "Making Informed Decisions." "All of this is to get people thinking, rather than jumping to conclusions," notes Fairfax. "If you get several yes’ answers [to the bulleted points] you should at least start thinking." The section includes the following:

• Current patterns of workplace contamination with anthrax spores: The anthrax exposures were confined to the East Coast, notes Fairfax. "If you are in, say, Bend, OR, you don’t need to be worried as much." Mail volume also is a consideration "If you’re in Seattle, for example, then mail centers in the area may need to have an elevated level of concern."

• The likelihood of the workplace being a target for Bacillus anthracis contamination: Clearly some key post offices, members of the news media and the Senate were targeted, but if you’re an employer who makes widgets in the middle of Iowa, you will probably not be targeted, Fairfax observes. "Look at the kinds of workplaces that have been a target, and see if there’s any sort of reason you could be as well," he advises. "Do you serve any of those places? How do you interact? If you’re a printer for CBS and you send them 1,000 copies of documents, your risk is probably very low. But if your job involves going to CBS and picking up materials then that, in my mind, would say you should have an elevated level of caution."

• The proximity of a workplace or workstation to areas known to be contaminated with anthrax spores: For example, some of the mail for the Department of Labor building comes from the post office’s Brentwood facility, which added to their level of concern, notes Fairfax.

• The likelihood of the workplace receiving mail or other items from a contaminated facility.

•Any information provided by law enforcement or public health officials about the workplace’s risk of receiving contaminated items: You could be contacted by local authorities about a potential risk, notes Fairfax. Or, you may open a letter and have, say, sugar fall out, in which case you should follow the procedures recommended by those local authorities.

• The amount of mail your workplace received: The more mail you receive, especially if it is received from a variety of areas, the more likely something picked up from a contaminated area could come through, says Fairfax. "Some places get a small amount of mail three days a week, while others get a truckload every day," he observes.

• The type of workplace: For example, a post office, bulk mail center, or public or private mailroom where contamination might be possible.

• The potential that workplace operations and tasks could result in exposure if contaminated mail is received: This could include handling mail, working on sorting machines, and so on, says Fairfax. "Try to get people focused on the jobs they do, and how they might potentially come in contact with anthrax," he advises.

• The use of high-speed mail handling equipment, or other processes that might aerosolize anthrax spores: High-speed mail-handling equipment utilizes rollers to move the letters along, Fairfax explains. They squeeze the letters and force the air out, and any spores contained in the letters are aerosolized. "That’s what killed the postal workers," he says.

• Any other information or analysis that would indicate the workplace might be contaminated with anthrax: "Maybe you had a threat come in by phone," Fairfax suggests. "Or you received a misdirected letter intended for a targeted department."

The Risk Pyramid

Occupational health professionals can use the answers to the questions posed above to assign a specific level of risk to their workplace. Those risk levels, illustrated by a pyramid on the OSHA web site, are as follows:

• Red Zone: Workplaces where authorities have informed you that contamination with anthrax spores has been confirmed or is strongly suspected.

• Yellow Zone: Workplaces where contamination with anthrax spores is possible.

• Green Zone: Workplaces where contamination with anthrax spores is unlikely.

"Employers should consider the factors listed above and use their knowledge of their own workplace, together with information about the anthrax threat from law enforcement organizations and public health departments, to determine the zone that best describes their workplaces," OSHA advises.

The pyramid also puts the risk, or lack thereof, more clearly into perspective. While the pyramid seems to indicate a fairly healthy representation of the red and yellow zones, "I would say that 99.999% of the facilities in the country are in the green zone, and a fraction of one percent are in the yellow zone," says Fairfax. "We just couldn’t draw the red zone like we wanted to."

"I totally agree with the OSHA people who indicate that there should be a very small part of the pyramid to indicate the workplaces that actually get the problem," says Udasin. "Yes, we know the problem exists, and yes, there is cross-contamination, but even there we’re not sure how high the risk is. For example, this woman [in Connecticut] who died of anthrax was 94 with chronic renal failure," she asserts.

In addition, notes Fairfax, you can proactively change your workplace’s risk zone. "Our location [near the Brentwood facility] initially pushed us out of the green zone and into the yellow," he notes. "But we closed down our mailroom and irradiated, then tested and checked for anthrax. We started to get clean mail, so we dropped back into the green zone."

(Conversely, after an employee of a hospital in New York City died recently of inhalational anthrax, area hospitals perceived themselves to be at a higher level of risk and swung into action. See "NY anthrax death spurs hospitals into action" in this issue.) Fairfax emphasizes that what you do with the pyramid and your self-ranking are in your hands. "These are voluntary suggestions from OSHA," he declares. If you do fall within the yellow zone, says Fairfax, he advises considering the voluntary provision of respirators or gloves. "There is a link on our site to respirator standards," he adds.

Use common sense

Clearly, no system — however thorough — can cover all possible situations. Are there other criteria occupational health professionals might consider as they wrestle with the anthrax issue? "What OSHA says about making informed decisions makes sense," says Udasin. "I was consulting with a company to help reduce their levels of concern. They had been in the World Trade Center and had to relocate. They received a package of white powder and went into panic mode. Somebody had nasal swab testing; she showed up with positive baccilus, but not anthrax. Everybody got extremely excited; they want all kinds of elaborate things done in the mailroom, but I advised against it. Unless you fit the pattern, or you have a prominent person who’s visiting, you shouldn’t be that worried. If you are a big, high-profile company that has a major defense contract, or you’re a very big, important company, you may fit the bill."

Otherwise, she says, common sense should prevail. "Things like keeping babies out of the workplace are always a good idea, whether it has to do with anthrax or not," she says. "But spending a fortune to get rid of anthrax when you’re not in a high-risk situation is just not worth it." Finally, she warns, there’s no way to assure 100% protection. "If you look at mail facilities, it’s difficult to sterilize the entire mail supply," she says. "It’s always a potential worry."

[For more information, contact:

• Richard Fairfax, CIH, director of compliance programs, OSHA, Compliance Programs, N3603, 200 Constitution Ave. N.W., Washington, DC 20210.

• Iris Udasin, MD, associate professor and medical director of the environmental and community medicine, UMDNJ Medical School, EOHSI Clinical Center, 170 Frelinghuyesen Road, Piscataway, NJ 08854. Telephone: (732) 445-0123. E-mail: udasin@eohsi.rutgers.edu.

• Additional OSHA Contact Information:

If you have an emergency: Call (800) 321-OSHA (6742). TTY: (877) 889-5627. Do not send mail.

If you have workplace safety and health-related questions: Call (800) 321-OSHA (6742).