MEMORANDUM

TO: All U.S. Local Unions, Trade Divisions, and Conferences

FROM: LaMont Byrd, Director Safety and Health Department

DATE: November 4, 2014

RE: Statement on the Ebola Virus Disease

The Teamsters Union is concerned with the health and safety of its members within the 22 divisions it represents. It is important that our members, who perform jobs that place them at higher risk of exposure, are informed about the recent threat posed by the Ebola Virus Disease (EVD). Currently, members in the Airline Division, Public Services Division, and Solid Waste and Recycling Division are directly impacted by the threat of occupational exposure to EVD. To assure protection for working people against possible exposure to Ebola, employers should establish and implement effective programs that comply with, and possibly exceed, the recommendations of the Centers for Disease Control and Prevention (CDC), those of state and local health departments, and the standards of the Occupational Safety and Health Administration (OSHA).

The IBT Safety and Health Department is actively communicating with representatives of various federal agencies, including the CDC and OSHA, and other trade unions regarding best practices for employee protection from Ebola exposure and transmission. This memo will provide brief information on the OSHA standards that apply, and guidance on where to find more information in a situation that is dynamic.

THE EBOLA VIRUS

The EVD is a rare and deadly disease which is transmitted from person to person by direct contact with body fluids of an infected person who has symptoms of EVD. Body fluids include saliva, mucus, vomit, feces, sweat, tears, breast milk, urine, and semen. The virus can persist outside the body for several hours to several days depending on environmental conditions.

CDC, STATE and LOCAL HEALTH DEPARTMENTS and OSHA GUIDANCE/STANDARDS

The CDC issues frequent guidance documents and updates regarding EVD protocols, best practices, and recommended Personal Protective Equipment (PPE) as new information is gained. State and local health departments do generally abide by CDC recommendations. Their mandate is to adopt emergency operations plans for Ebola response that address the concerns and unique needs of their state and local healthcare facilities, and assess the readiness within their jurisdiction's inpatient and outpatient healthcare facilities, clinician practices, and other clinical settings. (1)

Federal OSHA does not have an infectious diseases standard but California OSHA has incorporated CDC recommendations into its infectious diseases standard. Employers are required to follow the following OSHA standards:

    •    Bloodbome Pathogen (BBP) Standard - 29 CFR 1910.1030 (Airline included)

The employer should have a written exposure control plan (ECP) including an exposure determination analysis and employee training on its contents, training on proper PPE selection and use, infectious substance waste removal and handling procedures, housekeeping protocols, etc. Medical removal protection language in the event of an occupational exposure should also be included, as agreed to by the Union.

    •    Respiratory Protection Standard - 29 CFR 1910.134

In situations where workers may be exposed to bioaerosols containing Ebola virus, employers must provide to each employee, at no cost, adequate respiratory protection if engineering controls are not feasible. The employer shall provide respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, detailing required worksite-specific procedures and elements for required respirator use including fit testing, and training. Only NIOSH-certified respirators may be selected.

    •    Hazard Communication Standard- 29 CFR 1910.1200 (Airline included)

Employers are required to protect their workers from exposure to chemicals used for cleaning and disinfection of EVD surfaces and equipment. A written hazard communication program must be established listing all chemicals used and detailing proper container labels and markings, location of Safety Data Sheets, employee training etc.

    •    Personal Protective Equipment (PPE) Standard - 29 CFR 1910.132

Employers must assess the workplace to determine if hazards are present or are likely to be present, which necessitate the use of PPE. If such hazards are present, or likely to be present, the employer shall: select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment.

    •    General Duty Clause (OSH) Act of 1970 - 29 USC 654

Requires employers to keep the workplace free of recognized hazards that can cause death or serious harm to workers.

    •    Whistleblower Protection Act (General Industry) and Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR21) (Airline Employees)

This act prohibits employers from discriminating against their employees for exercising their rights under the OSH Act. These rights include filing an OSHA complaint, participating in an inspection or talking to an inspector, seeking access to employer exposure and injury records, and raising a safety or health complaint with the employer. If workers have been retaliated or discriminated against for exercising their rights, they must file a complaint with OSHA within 30 days of the alleged adverse action.

MORE INFORMATION

Ebola-related fact sheets have been placed in the Safety and Health Fact Sheets section of the International Brotherhood of Teamsters website. In addition, we have posted a headline news item on the home page of the website that highlights the fact sheets which can be accessed online at:

http://teamster.org/news/2014/1 O/ebola-fact-sheets-available-download.

The CDC website on Ebola can be accessed at http://www.cdc.gov/vhf/ebola/.

The OSHA website on Ebola can be accessed at http://www.osha.gov/SLTC/ebola/.

The National Institute for Occupational Safety and Health (NIOSH) website on Ebola can be accessed at http://www.cdc.gov/niosh/topics/ebola/.

For more information, contact the IBT Safety and Health Department at (202) 624-6960 or ibtsafety@teamster.org.

(1) Phone numbers for state and local health departments: http://www.cdc.gov/vhf/ebola/outbreaks/state-local-health-department-contacts.html