OLAW Online Seminar: Occupational Health and Safety Programs

OLAW Online Seminar

March 12, 2020

Ted Myatt, Sc.D., University of Rhode Island

Eileen Morgan, NIH, Office of Laboratory Animal Welfare

Building a Research

Occupational Health Program

OLAW FAQ G.9.: olaw.nih.gov/guidance/faqs#G

OLAW Online Seminar

March 12, 2020

Ted Myatt, Sc.D., University of Rhode Island

Eileen Morgan, NIH, Office of Laboratory Animal Welfare

Building a Research

Occupational Health Program

Occupational Health

and Safety Programs

Eileen Morgan

Director, Division of Assurances

Office of Laboratory Animal Welfare

National Institutes of Health (NIH)

Objectives

Identify Occupational Health and Safety

Program (OHSP) requirements per

PHS Policy and Guide

Indicate who is responsible for the OHSP

Identify essential components of an

effective OHSP

Requirements

PHS Policy IV.A.1.f.

For institutions with an Animal Welfare

Assurance, the Institutional Program for Animal

Care and Use must include a description of …

“the health program for personnel who work in

laboratory animal facilities or have frequent

contact with animals”

Requirements

Guide for the Care and Use of

Laboratory Animals, 2011 (p 17-23)

“Each institution must establish and maintain an

occupational health and safety program (OHSP)

as an essential part of the overall Program of

animal care and use.”

Requirements

Medical Evaluation and Preventative

Medicine for Personnel

• “…development and implementation of a

program of medical evaluation and preventive

medicine should involve input from trained

health professionals, such as occupational health

physicians and nurses.”

• “Confidentiality and other medical and legal

factors must be considered…”

Polling Q1

Components

of an OHSP

• Personnel Training

• Disaster Planning/Emergency Preparedness

• Risk Assessment

• Medical Treatment

• Facilities, Equipment & Monitoring

• Hazard Identification

• Health Assessment

• Personal Protection

Risk Assessment is an

Essential Component

Two parts to the risk assessment process

include:

• Identifying hazards associated with risks of

the job

• Identifying risks of the individual

Occupational Health and Safety in the Care and Use of

Research Animals, National Research Council, 1997

OLAW FAQ G.2. What is Required?

Pre-placement medical evaluation

Identification of hazards to personnel and safeguards

appropriate to the risks associated with the hazards

Appropriate testing and vaccinations

Training of personnel regarding their duties, any hazards,

and necessary safeguards

Personal protective equipment (PPE)

OLAW FAQ G.2. What is Required?

Policies and facilities that promote cleanliness

Provisions for treating and documenting job-related

injuries and illnesses

Facilities, equipment and procedures designed, selected

and developed to reduce the possibility of physical injury

or health risk to personnel

Good personal hygiene practices, prohibiting eating and

drinking, use of tobacco products, and application of

cosmetics and contact lenses in animal rooms and

laboratories

Summary

• The institution is responsible for

establishing and maintaining an effective

OHSP

• The nature of the OHSP will depend on the

facility, research, hazards, and species

involved …beginning with an identification

of those hazards and assessment of the

associated risks

• An effective OHSP requires evaluation of

program components and the coordination

of various research, program,

administrative, and facility personnel

Building an Effective Research

Occupational Health Program

Ted Myatt, Sc.D.

Associate Vice President for Research Administration

University of Rhode Island

Requirements for an Occupational Health

and Safety Program (OHSP)

PHS Policy IV.A.1.f.

For institutions with an Animal Welfare Assurance, the Institutional

Program for Animal Care and Use must include a description of “the

health program for personnel who work in laboratory animal

facilities or have frequent contact with animals.”

Guide for the Care and Use of Laboratory Animals (p. 17)

“Each institution must establish and maintain an occupational health

and safety program (OHSP) as an essential part of the overall

Program of animal care and use.”

Health Risks of Animal Care Staff

Veterinary services rank 2

in incidence rates for

non-fatal occupational injuries and illnesses

Types of injuries or illnesses:

Laboratory animal allergies, with progression to asthma

• 10-46% of exposed develop allergies

Needlestick/sharps injuries

Musculoskeletal disorders (MSDs)

Compassion fatigue, stress, burnout

Zoonotic infectious disease

Topics for Today

Confront the barriers

Improve upon what you have

Be inclusive

Go beyond the Guide

Consider the broader research community

Challenges and Barriers to an Effective OHSP

Lack of expertise

Lack of resources

Institutional barriers

On-campus health services focused on student health only

OHSP focused on clinical care, not research environment

Polling Q2

What Does Your OHSP Need to be?

“The nature of the OHSP will depend on the facility,

research, hazards, and species involved.” (Guide, p. 17)

Start by evaluating the risks

Conduct an assessment of all activities involving

animals

Building an Effective Program

Based on your risks, understand

program needs (i.e., time, resources)

It’s OK to start small

Utilize outsourced expertise wisely

Build in training opportunities

Program needs champions

 Leadership and doers

Regardless of size, a successful

program requires a team

approach

Hallmark of an

Effective Program?

Sound Implementation

Strategies

Focus on developing sound,

realistic policies and

procedures

Engage Leadership Gain Support

Engage

Proactively discuss regulatory requirements

and risks with senior leadership

Data – conduct a gap assessment

Internal or external

Compare against requirements and

peer institutions

Survey program users

Rate status of program areas

(e.g., not present, developing, mature)

Hallmark of an

Effective Program?

Strong Administrative

Support

Challenge – Lack of a Broader OHSP

No on-site occupational health program

List of providers as opposed to an occupational program to

“integrate” into

Urgent care is first line of treatment

State-run programs

Connect with institutional risk management

Example Situation

Growing Research Institution

No on-site occupational health service

No occupational health expertise in-house

Used biomedical research focused occupational health consultant

to provide remote support (i.e., medical evaluations)

Used consultant to train in-house staff

Gradually expanded in-house programs

Be Efficient

Use available capabilities

and services

Use Health Services

electronic medical

records system for animal

contact medical

surveillance and

respiratory protection

medical evaluation

Improve Your OHSP – Learn, Grow, Evolve

Programs should be ever changing

Semiannual IACUC program review is a good mechanism for

self-evaluation

Identify funds for training opportunities

Improve your logistics

Make interacting with the program as easy as possible – consider the

researcher’s perspective

Can communication between offices be improved?

Interact with Human Resources to connect immediately with new hires

Interact with Enrollment Services to obtain student rosters for classes

that involve animal contact

Be Inclusive – Go Beyond the Guide

NIH Guidelines for Research Involving Recombinant or Synthetic

Nucleic Acid Molecules

OSHA Standards

• 29 CFR 1910.1030 Bloodborne Pathogens

• 29 CFR 1910.95 Occupational Noise Exposure

• 29 CFR 1910.1048 Formaldehyde

• 29 CFR 1910.1450 Laboratory Standard

Nuclear Regulatory Commission Standards and Regulations

Include Everyone

Protections for:

• pregnant women;

• immunocompromised

individuals; and

• People not involved with the

animal care and use program

(e.g. visitors, students,

maintenance workers,

emergency workers)

• Ensure your

institution does not

limit services to

those with animal

contact

• What about staff or

students that do not

have contact with

animals?

What Does a Program Look Like?

Animal Exposure

Medical surveillance program, health history questionnaire,

tetanus vaccination

Employees who handle wild animals will be provided rabies

vaccinations

Biological Materials

Laboratory workers who handle pathogens for which there is an

effective vaccine available will be provided vaccinations for those

agents

Reproductive Concerns

Laboratory workers who handle materials for which exposure may

result in potential reproductive and developmental concerns will be

provided risk evaluation and medical advice

Respiratory Protection

Laboratory staff may necessitate the use of a respirator due to medical

considerations or exposure to allergens or hazardous materials

Connect with EH&S to provide fit testing

Other Occupational Injuries

What Does a Program Look Like?

Example Situation

Clinical Care Focused Occupational Health Program

Robust clinical care occupational health program

Large research program

Beyond basic support for animal care staff (i.e., allergen exposures),

there was a lack of understanding of other occupational risks

Work to incorporate research issues into larger occupational

health program

Engaged OHSP team to participate in research-related functions to

learn about research health risks (e.g., attending IBC, IACUC)

Established lines of communication with local emergency

department to facilitate care the event of exposures

Improve Your OHSP

Continue to develop resources

Medical SOPs for health

providers

Agent specific training, hazard

specific training

Expand to new areas

Ergonomic evaluations

Hallmark of an Effective

Program?

Ensure Coordination of

Program Components

Meet regularly with

stakeholders

Build Awareness

IACUC policy requires participation

IACUC research protocols and courses

that involve exposure to animals

IBC policy

Communications with faculty, staff,

and students

Website, flyers, and magnets

Involve the Community Gain Support

Demonstrate the value of the OHSP

Publish annual progress reports

Ask for feedback

Questions

Submit to the chat box in the

GoToMeeting control panel

Question 1

Can you provide possible

approaches or options that Assured

Institutions may implement

regarding completion of a medical

evaluation?

Question 2

My institution involves using

animals in teaching. What is the

expectation for the oversight of the

students in an OHSP?

Question 3

Part I

A PI considering writing his own IACUC

training protocol for rodents. It involves

participants who will observe the procedure

and others who will have an opportunity to

perform hands-on surgical procedures.

What are the Occupational Health

requirements for participants observing

animal procedures and for participants

manipulating or performing the animal

procedures?

Question 3

Part II

What is the most effective

composition of the Occupational

Health Program that would be

amenable for a small university with

few resources (e.g., no adjunct

medical school)?

Question 3

Part III

What are the different models that

universities use to fulfill NIH

requirements (e.g., external

contracts, relationship with

hospitals)?

Question 3

Part IV

Who is responsible for ensuring

that there is an Occupational

Health Program and where does

this program fit in the structural

organization of the institution?

Question 4

How can institutions and their

IACUCs best prepare for a

coronavirus pandemic?

Question 5

Part I

Can OLAW provide guidance to

institutions that are unable to

conduct semiannual facility

inspections at least once every 6

months as a result of a complete

shutdown due to COVID-19 and/or

where only essential personnel are

allowed into facilities?

Question 5

Part II

If OLAW authorizes a waiver

regarding conducting semiannual

facility inspections within the 6

month timeframe as a result of

COVID-19, will institutions be

allowed to “pick up where they left

off” or will they be required to

“catch up”?

Question 6

If procedures on an IACUC-approved

activity cannot be performed (e.g.,

administration of post procedural

analgesia) as a result of a facility closure

due to COVID-19, would that be

considered reportable noncompliance

to OLAW?

Question 7

What should institutions do in the event

surgical masks or N95 respirators are not

available for purchase due to shortages?

CDC Recommended Guidance for Extended Use

and Limited Reuse of N95 Filtering Facepiece

Respirators in Healthcare Settings:

cdc.gov/noish/topics/hcwcontrols/recommendedguidanceextuse.html

CDC Strategies for Optimizing the Supply of N95

Respirators

cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy/index.html

Question 8

What provisions should be made if

an institution is unable to provide the

support, resources, or services to

maintain a compliant animal care

and use program (e.g., shortage of

available animal care personnel)?

Question 9

We have students that take classes

on a farm. How should we handle

their occupational health needs?

Question 10

We are almost finished with our

Assurance renewal writing for

submission, but with our institution is

preparing for a shut-down/slow-down

due to COVID-19, my fear is that it may

not be submitted to OLAW in a timely

manner. Is there any accommodation

for business that is “not as usual”?

Questions

Submit to the chat box in the

GoToMeeting control panel

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