Purpose

The purpose of this Health and Safety Instruction (HSI) is to reduce the health risk of using animals in research and teaching to an acceptable level.

Background

Many different kinds of physical, environmental, or biological hazards are associated with the use of animals in teaching or research (Table 1).  Requirements for an occupational health program for personnel working with laboratory animals are found in Biosafety in Microbiological and Biomedical Laboratories published by the Centers for Disease Control and Prevention and the National Institutes of Health; Code for Federal Regulations, Title 10, Part 20 and Title 29, Part 1910; the Public Health Service Policy on Humane Care and Use of Laboratory Animals that codifies the Guide for the Care and Use of Laboratory Animals (Guide) published by the National Research Council; and, Occupational Health and Safety in the Care and Use of Research Animals published by the National Academy of Sciences.  A description of the occupational health program must be included in the Assurance of Compliance that is required by the National Institutes of Health.  The Association for the Assessment and Accreditation of Laboratory Animal Care (AAALAC), International conducts triennial inspections to assure compliance with all applicable occupational health and safety standards.

Under standards outlined in the Guide, the program components must include:

• Hazard Identification and Risk Assessment

• Personnel Training

• Personal Hygiene

• Facilities, Procedures, and Monitoring

• Personal Protection

• Medical Evaluation and Preventive Medicine

This HSI, developed by the Occupational Health and Safety Committee (OHSC) and revised by the Animal Hazards Program Committee, serves as the University of Arizona’s (UA) written policy for occupational risk reduction for those using or exposed to animals in research or teaching.  Any regulatory penalties or medical costs resulting from noncompliance will be charged in accordance with standard university policy.

Participation Requirements

Personnel included are those involved in the direct care of animals and their living quarters and those individuals who have direct or environmental contact with animals (live or dead), their viable tissues (i.e., formalin fixed tissues are excluded), body fluids or wastes.  The assessment of risk will be determined by frequency of contact, intensity of exposure, hazards associated with the animals being handled, hazardous properties of agents used in research, the susceptibility of individual employees, the hazard-control measures available, and the occupational history of individual employees.

This includes all:

·             University Animal Care (UAC) staff

·             investigators and their technical staff

·             instructors and students involved with animal related work.
 

and some personnel in:

·             facilities management

·             security

·             custodial services

As well as certain students, consultants, volunteers and visiting scholars.

Non-University of Arizona students or employees who will be performing animal work as defined above at the University of Arizona must also comply with this HSI.  Documentation of meeting the AHP components must be filed with the Occupational Health Service [OHS] (http://www.health.arizona.edu) before the commencement of the work.  The OHS can perform medical procedures on non-university students or employees in some circumstances.

1. Personnel who work solely with standard animal biological products such as organs, tissues, cells, or antibodies obtained from vendors may be exempt from program participation.  In order to qualify for exemption, a current animal health report from the vendor must be supplied to the University Animal Care clinical veterinarian for review and approval.

2. Personnel whose OSD has signed the exemption statement on the Risk Assessment Questionnaire, which states that they will have no contact with animals, animal tissues, fluids or wastes, nor will they enter animal areas.  This is often administrative personnel who are listed on a protocol.

3. Personnel whose contact is limited to in-vitro work with animals, tissues, fluids or wastes that have been sterilized chemically or via autoclaving.

Explanation of Key Terms
 

Risk is a statement of probability that harm, injury, or disease will occur in the occupational setting.  The degree of risk can, and does, vary with an assortment of factors.

Risk assessment is the evaluation of scientific information on the hazardous properties of an agent and on the extent of human exposure that yields a qualitative or quantitative statement of the probability and degree of risk or harm estimated for individuals or populations.

Hazard is a recognized risk.  Once a risk is recognized and assessed, appropriate adjustments can be made to modify the underlying factors that contribute to the risk, or behaviors can be modified to reduce exposure to those risks.  The risks can be abated through engineering controls, personal protective equipment, and by administrative control to include: modifying practices and procedures, pre-placement and periodic examinations, training, etc.

Safe is the state of being free from risk or when an acceptable level of risk has been achieved.

How it Works

Participants are assigned a category(ies) that reflect the general surveillance needs of the individuals based on real or potential occupational exposure to specific species of animals.  The assessment of risk will also be based upon frequency of contact, intensity of exposure, hazards associated with the animals being handled, hazardous properties of agents used in research, the susceptibility of individual employees, the hazard-control measures available, and the occupational history of individual employees.

Requirements

1. Enrollment in the Animal Hazard Program must occur prior to the employee’s or participant’s exposure to animals, their viable tissues, body fluids, or wastes.   It is a requirement for IACUC certification. Enrollment consists of completing and submitting the Animal Hazards Risk Assessment Questionnaire to the Occupational Health Service.
    

2. All participating faculty, staff, employees, students, and volunteers will be queried via the University of Arizona’s Risk Assessment Questionnaire regarding anticipated exposure to animals.  The Risk Assessment Questionnaire may be obtained from the Occupational Health Service (621-2568), is available at the “Introduction to Animal Hazards Program” training class, or may be downloaded from the Institutional Animal Care and Use Committee’s web page (http://www.uac.arizona.edu/forms/uacformspage.shtml). 
    

3. Every lab must appoint one individual that serves as the Occupational Safety Designee (OSD).  This individual, along with the Principal Investigator (PI), is responsible for occupational safety concerns for their research group (see Figure 1).  Protocol forms provide a space for PIs to indicate their OSD.  Any protocols submitted without a specified Occupational Safety Designee will not be routed for IACUC review.
    

4. The appropriate administrative staff in support departments, such as Facilities Management and Security, will determine which employees are to be enrolled in the program (those at risk through environmental exposure – no direct animal contact, Category 8).
    

5. Individuals who have not registered with the Animal Hazards Program are subject to having facilities access denied and protocol authorization/participation withdrawn.
    

6. Education:
    

   1. All persons participating on any IACUC reviewed and approved project must receive certification to "Introduction to the Animal Hazards Program" and "Laws and Regulations: located at www.iacuc.arizona.edu/training. Topics presented as employee information will include, but are not limited to:
       

      1. Program function and coverage description

      2. Important zoonoses of animals

      3. Points of contact for additional information

      4. Provision of informational handouts on topical matters.
          

   2. OSD Requirements:  The OSD for each research group is responsible for assuring that all members of the research group are adequately informed of, and receive training in, Occupational Safety issues, and are in compliance with program requirements (See Figure 1).  The Occupational Safety Designee (OSD) will need to attain certification in all species specific classes on zoonotic diseases that are germane to the specific areas of research undertaken by the research group.  The PI and OSD may choose how best to train members of the individual research group in these issues, which may include their also taking the zoonotic disease classes.   If the PI./OSD choose to provide training to staff, they must document content and attendees.
       

   3. All persons should have completed the ‘Introduction to Animal Hazards Program’ class as soon as possible and not longer than four months after their initial hire date.  If a Principal Investigator has not received proper certification, their protocols will not be reviewed for approval.  Technicians/Participants who are not properly certified will not be authorized to participate on protocols.
       

   4. Training will be under the auspices of the IACUC.  The Department of University Animal Care (UAC) and the OHS will provide technical instruction and assistance.

Reporting Injuries and Infections

1. Duty Site Surveillance of Work Related Injuries:

   1. Injury and Infection Log: Every animal holding facility and animal research laboratory will maintain an Injury and Infection Log to include the following categories:
       

      1. Date of injury or infection

      2. Time of injury or infection

      3. Type of injury or infection

      4. Date of employee referral to OHS

      5. Time of employee referral to OHS
          

   2. Reporting Work Related Injuries: Every person working with animals should be aware of the potential danger from animal bites. Although an animal scratch or bite might not seem serious, its occurrence should be reported to one's supervisor or instructor so that proper measures may be taken.  In addition, employees and students shall promptly report all suspected work related injuries and illnesses:
       

      1. Weekdays between 8 a.m. and 4:30 p.m., Wednesdays between 9 a.m. and 4:30 p.m.: Report to the Occupational Health Service (621-4427) at the Campus Health Center.

      2. After work hours: Report to any Urgent Care facility or Emergency Room and inform them that your Workers’ Compensation Carrier is the Arizona Department of Administration, Risk Management Section.

      3. When an injury or illness has occurred, a Supervisor’s Report of Employee Injury/Illness form (http://fp.arizona.edu/riskmgmt/insurance_forms_on.htm) must be filed with the UA Department of Risk Management and Safety within 7 calendar days.

3. Several of the agents responsible for viral, bacterial, and parasitic infections in laboratory animals are capable of infecting humans.  Employees are counseled to report any gastrointestinal, eye, respiratory or skin illnesses that may resemble the signs or symptoms of infections in the animals for which they are caring.

Personal Hygiene

1. There are a number of personal hygiene issues that apply to all workers who are exposed to animals.

   1. There should be no eating, drinking, smoking, or applying of cosmetics in areas where animals are housed or used.

   2. Laboratory coats should be worn over street clothes when working with animals - this will minimize the contamination of street clothing.  Laboratory clothes should be left in the lab and should not be worn when eating or in public eating areas.  Laboratory clothing should be laundered routinely - see chemical hygiene plan.

   3. Careful hand washing should be done after handling of animals and prior to leaving the laboratory.

   4. All work surfaces should be decontaminated daily and after any spill of animal related material.

   5. Certain infections are transmitted from animals to humans primarily by the animal feces or urine contaminating someone’s hands and then contaminating objects put into the mouth.  Examples of organisms utilizing this mode of transmission are species of Salmonella, Shigella, and Entamoeba.  Every precaution should be taken to avoid this mode of transmission by alertness and careful personal hygiene.  Additional health problems are encountered when these organisms are carried home and children/family members are exposed.

Occupational Health Provisions

1. Basic Occupational Health Care (BOHC):

1. Care Plan:

   1. Prior to beginning animal work, all participants must receive certification in Introduction to Animal Hazards program.  Submission of the Risk Assessment Questionnaire is part of the IACUC certification requirements.  The Risk Assessment Questionnaire must be updated whenever an employee changes jobs or animal species, or as deemed necessary by the Animal Hazards Committee or Occupational Health.

   2. The questionnaire will be reviewed by the Occupational Health Service and a clinic visit may be scheduled depending on level of risk or in accordance with specific job requirements.  If not otherwise required, individuals may decline the clinic visit, but must file a formal declination with Occupational Health.  This information will be forwarded to the OSD or supervisor for their records.

   3. The recommendations made by the provider at the visit will be based on the functional requirements of the position, the type of animal contact, and the individual’s medical history.  Any persons declining to obtain recommended inoculations or testing will be required to sign a declination form.  This information will be forwarded to the OSD or supervisor for their records.

2. Surveillance Recall:  Employees and students (participants) who are enrolled in the Animal Hazards Program are periodically recalled for medical follow-up depending on the specific types of animal exposure.

   1. Surveillance Recall Schedules: See Table 4

   2. Notices for surveillance are sent to the employee and/or employee's OSD or supervisor and appointments scheduled with the OHS.

   3. The OSD/PI/Supervisor is/are notified of an employee's or individual's participation in the surveillance program via memo or email from the OHS.  The IACUC and the OSD/PI/Supervisor is/are informed of an employee's non-participation, noncompliance or submission of a declination to participate with the program by memo or email.

3. Diseases/Immunizations: Participants, depending on their specific exposure, will have the following vaccinations documented:

   1. Tetanus Prophylaxis: The Public Health Service Advisory Committee on Immunization Practices (ACIP) (http://www.cdc.gov/nip/publications/acip-list.htm#Vaccine) recommends immunization against tetanus every 10 years for everyone. It is also recommended if a particularly tetanus-prone injury occurs in an employee where more than five years has elapsed since the last immunization. Every employee should have up to date tetanus immunizations.

Bites and Scratches: any wound may potentially serve as a source from which tetanus may result.  A trained health care provider will evaluate all wounds to assess contamination and likelihood of infection, as well as determine proper treatment.  Tetanus boosters are required every 10 years.  If a wound occurs, persons who have previously received a full primary series of tetanus immunizations may not require a booster if less than 5 years has elapsed since the last immunization.  This is dependent, however, upon severity of the wound, degree of contamination, and circumstances surrounding the injury.  It is strongly recommended that all wounds be seen and treated despite the person’s status of tetanus immunization.

2. Rabies is a relatively rare and devastating viral disease that can result in severe neurological problems and death.  Most cases of rabies occur in wild animals although any mammal can contract the disease.  The disease is virtually unheard of in common laboratory animals.  The exception to this is with dogs and cats.  At the University of Arizona, random source research dogs and cats are vaccinated against rabies and are quarantined for 14 days.  All bites of any type should be reported immediately to one’s supervisor.

   Rabies is an endemic disease in Arizona, especially in skunks, foxes, and bats.  Sporadic cases have been well documented in other species of wildlife, as well as domestic animals.  Animals and animal tissue field-collected in Arizona should be handled with care.  Precautions should take into account that infected animals may shed the virus in the saliva before visible signs of illness appear, that a bite is not required to contract rabies - contact with saliva may be sufficient, and that rabies virus can remain viable in frozen tissues for an extended period.  (http://www.health.arizona.edu/pdf/rabies-info.pdf).

   Based on current ACIP (http://www.cdc.gov/nip/publications/acip-list.htm#Vaccine) recommendations, rabies pre-exposure prophylaxis with human diploid cell rabies vaccine (HDCV) is provided to the following employee groups:

   1. Those working directly with the rabies virus,

   2. Those having random source dog and cat contact,

   3. Those having direct contact with Categories 2, 3, 4, and 5 animals,*

   4. Those having exposure to potentially infected animal body organs or performing post   mortem examinations on animals with a history of poorly defined neurological disorders,

   5. Those having responsibility for capturing or destroying wild animals on University of Arizona property (excluding birds and rodents),

   6. Wildlife mammalogists and students engaged in the handling and/or capture of susceptible species.

   4. Post Exposure - See Table 3

   5. Participants may formally decline this prophylactic vaccine and may still participate in other parts of the program.

   6. Serologic monitoring and booster doses:

   7. Serologic monitoring will be performed every two years.

   8. Booster doses are administered to employees with inadequate titer.   Inadequate titer is defined by the Centers for Disease Control and prevention as <1:5 by the rapid fluorescent focus inhibition test.

*At the University of Arizona, the CDC “Frequent Exposure” classification is applied to all members of these categories.  In reality, many or most have only “Infrequent Exposure”.  These exposures are based more on the prevalence of rabies in the Southern Arizona fauna than on actual human exposure to the virus. Field workers are occasionally exposed to rabies, but laboratory and animal care workers are not.  Dogs and cats used in research are vaccinated.  Bats and certain other wild animals transmit the vast majority of rabies.  Only under exceptional circumstances is a wild animal present in a UofA facility.

Farm animals are monitored, protected and in some cases vaccinated, however are subject to attack by bats as well as other wild and domestic rabid species.  Field researchers, while not always working directly with rabies prone species, are at increased risk due to greater environmental exposure.  Veterinary Diagnostic Laboratory workers, Veterinarians and researchers that utilize the rabies virus in their protocols are at “Frequent or Continuous” risk of rabies exposure.  These groups need to be immunized against rabies.

For this reason, the Animal Hazards Committee, in its January 24, 2007 meeting, elected to suspend routine rabies immunization and serology for all participants except:

1.      Field researchers that closely handle, study or trap rabies prone species.

2.      Other field or agriculture researchers who spend sufficient time in the field, or overnight, so as to be at risk for random exposure from indigenous rabies prone animals.

3.      Veterinary Diagnostic Laboratory workers

4.      Veterinarians

5.      Any participant working in a laboratory where the rabies virus is present

6.      Occasional others with individual situations/needs.

7.      In adherence to the Americans’ With Disabilities Act, and Arizona law, no individual will be required to receive rabies immunization.  Declination of the vaccination, may, at the discretion of their supervisor, preclude employment in certain positions and assignment to certain duties.

3. Influenza Immunization:  Based on CDC recommendations (see: http://www.cdc.gov/flu/avian/professional/possible-exposure.htm), all individuals who will have contact with birds or poultry, or who will be working with the influenza virus in a laboratory setting, should receive the annual influenza immunization.

For those working with birds/poultry, currently available “Flu vaccines” do not directly protect humans from acquiring Avian Influenza.  However, individuals that work with birds could acquire both the Avian flu and the Human flu, concurrently.  The result could be potentially life threatening AND, the affected individual could become a human incubator offering the two viruses the opportunity to combine in to a new, devastating human influenza.

4. Testing

   1. Participants in certain categories will have either semi-annual Tb skin testing (TST) documented.

   2. Other programs may be included, such as the Hearing Conservation Program  (http://fp.arizona.edu/riskmgmt/hearing_conservation.htm) and the respiratory Protection Program(http://fp.arizona.edu/riskmgmt/respiratory_protection.htm). See Figure 2 for guidelines on respirator use based on exposures.

2. Other Diseases/Issues

1. Allergies:   Allergy to animal hair and dander is common and therefore one of the more important occupational problems occurring in workers exposed to animals.  Allergies can be manifested in a number of ways, including: allergic rhinitis (a condition characterized by runny nose and sneezing similar to hay fever); allergic conjunctivitis (irritation and tearing of the eyes); asthma; or atopic dermatitis (a skin condition which is caused by contact with a substance to which an individual is allergic).  Allergy to animals is particularly common in workers exposed to animals such as cats, rabbits, mice, rats, gerbils, and guinea pigs.  Allergic reactions can be caused by exposure to dander and debris from the skin and fur of an animal, urine, saliva, or fecal matter.  Exposure to animal urine or feces may occur either through direct urine contact with skin or more commonly by inhaling dust from the bottom of a cage that has been contaminated with urine or fecal material.

People who have a prior personal history or family history of hay fever or eczema will be more likely to develop asthma after contact with animals.  These people do not seem any more likely to develop rhinitis and conjunctivitis than do those without such personal or family history.  Everyone should exercise certain precautions to attempt to prevent animal allergy.  These attempts should not be focused only on people with an atopic or allergy history.  Symptoms can develop anywhere from months to years after a person begins working with animals.  A majority of the individuals who are going to develop symptoms will do so within the first year.  It is extremely unusual to develop symptoms after more than three years of animal contact.  Certain procedures should be routinely followed in order to prevent the development of animal allergy.  Animals should be worked with in well-ventilated areas to prevent build up of various particles in the air.  Workers may want to wear gloves to prevent direct exposure to animals - this applies to animal urine and feces as well as to animal dander.  In order to prevent inhaling contaminated material, cages should be changed frequently and respirators should be worn during the changing of cages.

Despite the best preventive techniques some individuals will develop an allergy after contact with laboratory animals.  Rarely, this will be so severe that a person is forced to change his line of work.  More commonly, this can be controlled with the increased use of respirators while working with animals and possibly medication.  Desensitization therapy (allergy shots) has been successful for some individuals.  Employees will be queried on allergy risk

1. Employees at increased risk for developing work related allergies include those with a history of pre-existing allergies, asthma, seasonal rhinitis, or eczema.  These individuals may be referred to Risk Management for the Respiratory Protection Program.

2. Enrollees with suspected allergies will be encouraged to seek evaluation through the Occupation Health Service.

3. Referral for allergy testing will be provided to employees at the discretion of the Occupational Health Service and with the employee's consent.

For more information on allergies: http://www.cdc.gov/niosh/animalrt.html

2. Q Fever:  Q-fever is a disease caused by the microorganism Coxiella burnetii which can be acquired by exposure to placental membranes and fetuses from infected sheep or goats.  There is an especially high concentration of these infected materials in animals at the time that the animals give birth, so particular care needs to be used in handling newborn animals, placental tissues, and other products of conception.  This would include the placenta, amniotic fluid, and blood or soiled bedding.  In addition, individuals who handle young sheep or goats up to six months of age are at higher risk, as are individuals who participate in the routine care of sheep or goats such as the animal care workers.  This infection is extremely contagious and has been reported to be spread by aerosol.

It is extremely important that, should an employee who works with sheep or goats develop an influenza type infection, he/she mention to their physician the possibility of Q fever.  Q fever is something that would not routinely be thought of and this diagnosis is often missed.

Individuals with congenital heart disease, prior valvular heart disease, or who have a chronic immunocompromised state should not work with infected animals at the time of animal parturition (birth process), and it is best that they not work with sheep and goats at all (determined on a case by case basis).  Immunocompromised individuals would include those with AIDS or a positive blood test for the AIDS virus (HIV), or immunocompromised because of medications or certain chronic diseases.

In order to limit the spread of Q fever, the IACUC has a separate compliance policy for all personnel working with female sheep and goats (http://www.iacuc.arizona.edu/policies/approvedpolicies.htm).

At the time of the enrollment exam, employees are assessed for their likelihood of developing chronic sequelae should they acquire Q Fever.  Those employees with valvular or congenital heart defects, or those who are receiving immunosuppressant drugs, or splenectomized are advised of the potential risks involved and medical clearance for employment will be determined by the OHS on a case-by-case basis.

3. Toxoplasmosis:  pregnant women should be cautioned about working with cats in the laboratory setting.  Pregnant animal technicians who have been assigned to cat husbandry duties should be reassigned to other jobs during pregnancy unless titers are sufficient (see 1. below).  Pregnant women who are exposed to cats in other ways would be best to avoid this exposure.  There is no vaccine to protect humans

Toxoplasmosis antibody titers are determined on any female employee of childbearing capacity who is occupationally exposed to cats or their feces.  A negative IgM test and an IgG antibody of  <1:1000 IU/ML indicates immunity and no active infection is present.

Females of childbearing capacity who lack immunity and plan to work with cats are informed of their susceptibility and provided additional educational information on toxoplasmosis. Her supervisor will be advised (if requested by the employee) to consider arranging a temporary job reassignment while a susceptible employee is pregnant.  When this is not possible, consultation with the OHS will be encouraged to identify alternative methods of employee protection.

4. Nonhuman Primates

A large number of illnesses can be passed from non-human primates such as monkeys to humans and from humans to non-human primates.  Because of this, it is extremely important that employees exposed to or handling monkeys exercise particular caution.  Protective clothing should always be worn, especially when confronting primates.  Awake animals (not used to being handled) should be handled only while wearing bite proof gloves.  Ideally, animals should be sedated before procedures are performed.  Employees who are ill should not work with monkeys since they may transmit diseases to the monkey.  Personal hygiene must be scrupulously maintained by all those exposed to non-human primates.  Any scratch, bite or eye exposure must be immediately treated in accordance with instructions posted in the lab or treatment room and then reported to the supervisor.

1. Tuberculosis: Tuberculosis can be devastating in a monkey colony - special precautions are taken for individuals working with non-human primates, their products, or care devices.  Periodic tuberculin skin testing (TST) is performed every six months for all employees or participants with non-human primate, product, or device contact.  To avoid misinterpretation of what is known as a “boosted reaction,” a two-step PPD may be required for those beginning a tuberculosis screening program or who have not had a PPD within 12 months.  A chest x-ray is performed at an initial positive PPD reading or if there are symptoms indicated on the Positive TB Questionnaire, or as recommended by the CDC.  If the chest x-ray is negative, they are referred to their PCP or the County Health Department for treatment of latent Tb.
    

2. Rubeola (measles): Measles is a deadly disease in non-human primates and has become more common.  Nonhuman primates are vaccinated against this disease to prevent transmission from humans.  Persons with active cases of measles will be prohibited from any primate facility.
    

3. Cercopithecine herpesvirus 1 (Herpesvirus simiae or B-virus):  TC "CERCOPITHECINE HERPESVIRUS 1"\l 1 Herpes B or Herpes simiae causes a very minor illness in macaque monkeys, but can cause a fatal illness in humans who contract the disease.  In humans, it causes severe neurologic disease that is most frequently followed by death.  Fortunately, transmission of this disease to humans is quite rare.  As mentioned above, it is mandatory that caution be exercised and that a supervisor is notified immediately regarding any bites, scratches, or exposure of monkey excretions to mucous membranes or the eyes.  Medical care must be obtained.  Any wound should be carefully cleaned.  Once a wound has been acutely managed, any unusual manifestations that develop later also need to be promptly reported.  Symptoms of Herpes B infection at a wound include pain radiating away from the bite wound or blisters at the site of the wound.  Again, it must be emphasized that careful adherence to safe handling procedures is the most important step in preventing illnesses.
    

   1. Since there is not a vaccine for this disease, training in proper primate handling and care is essential. Additionally, wound management procedures will be reinforced during primate training sessions.  These procedures are posted in the animal room and inside Monkey Exposure Kits.

   2. Injury & Infection Log: Record all traumas (animal or cage) in the “Injury and Infection Log,” which is maintained by the facility supervisor.

   3. The University of Arizona adheres to the guidelines found in the publication  

      Recommendations for Prevention of and Therapy for Exposure to B Virus, CID     2002:35;1191-  12030.

BOHC Recommendations by Category

Please see Table 4 for specific recommendations by category.  Final recommendations for BOHC will be based upon individual risk assessment and may vary from the above.

Enforcement and Compliance

1. PROCEDURES FOR REGULAR INSPECTIONS OF THE WORKPLACE

   1. Introduction.  To achieve the University’s goal to provide and maintain the highest standard of health, safety and welfare for its staff, and in accordance with this HSI, systems must be in place to identify hazards in the workplace in order to allocate appropriate resources and implement effective control strategies.  The University recognizes that regular health and safety inspections are effective mechanisms for identifying workplace hazards.  The Animal Hazards Program requires each animal use unit to:
       

      1. Inspect the work area for hazards on a frequent and systematic basis, and document and evaluate the findings.

      2. Analyze and monitor work practices, procedures and systems of work to identify hazards which may otherwise be overlooked; and

      3. Develop and implement a priority action plan for hazard control
          

   2. These inspection reports will provide a monitoring system for OSD's of units.
       

   3. The Occupational Health Service is available for advice and assistance, but is not charged with the responsibility to accompany inspection parties.  The following guidelines have been developed to assist Units in the inspection process and may be adapted to suit individual areas.  In addition, the University’s regular seminars for supervisors and staff will include a segment on inspection procedures.
       

   4. Risk Management and/or Health and Safety Representatives may be invited to participate in the inspection, consulted when determining priority for action, and when implementing control strategies.  Interested employees should also be invited to participate.
       

2. DEFINITION
    

   1. Regular health and safety inspections are effective tools in the hazard identification process.  Together with accident investigation, these inspections form the main thrust in good occupational health and safety management.  Not only do they provide an opportunity to identify the sources of potential hazards, but can be used to monitor occupational health and safety policies and procedures and determine how effectively these are translated into the workplace.  The inspection process allows a full examination and report on the status of occupational health and safety performance in a work area.

   2. Essentially, it allows one to:

      1. identify hazardous conditions and apply hazard control measures

      2. monitor behavior trends

      3. monitor and evaluate health and safety standards

      4. improve health and safety standards

      5. measure performance

      6. check new facilities, equipment, processes, etc.

      7. collect data for meetings, support of initiatives, etc.

      8. maintain interest in health and safety

      9. display supervisory commitment to health and safety

   3. As a bonus, it has a noticeable effect on communication in the work area and thus helps to improve and facilitate industrial relations and enable the whole University community to play a more significant role in the maintenance of a healthy and safe work environment.  However, it must be recognized that the full benefit of the inspection process cannot be realized if action is not taken based on the data collected.
       

3. INSPECTION PROCEDURES

1. Who conducts the inspection?

   1. The inspection team should be comprised of at least two individuals.  The OSD and one of the following:

      1. the Principal Investigator

      2. manager of the unit

      3. a management representative, e.g., the relevant supervisor

      4. a workplace employee representative
          

   2. The Chair of the department or Manager of the unit should be immediately notified of any and all discrepancies noted during the inspection, and must sign the University of Arizona Animal Hazards Program Identified Hazard Summary Sheet prior to its being filed with the IACUC office.
       

2. When to inspect?

   1. A joint inspection of the type described above should be done at least on an annual basis, and is recommended on a quarterly basis depending on the area.  However, the OSD or supervisor should monitor the workplace on a daily basis (i.e., housekeeping, observation of behavior trends) and more formally on a weekly - biweekly routine, checking such things as environmental conditions, etc.  Any identified hazardous situations should be closely monitored at all times, particularly while awaiting the implementation of effective control measures.

   2. Vary the time of inspection to assure it is capturing the workplace as it really is (i.e., unprepared).
       

3. How to inspect?

   1. The Inspection Process:

(1)        Using the University of Arizona Animal Hazards Program Health and Safety Checklist and Inspection Report Form ( (http://www.uac.arizona.edu/forms/uacformspage.shtml)  as a guide, the inspection team should inspect all workplaces within the unit including office, storage, and maintenance areas.  Previous Inspection Reports should be viewed prior to inspection.

(2)        The inspection party should use the inspection checklist to consider:

(a)        Workplace Design (i.e., the physical workplace)

i.          ensure meets relevant legislative requirements

ii.         ensure correct storage facilities

iii.        assure ease of manual handling (a floor plan is helpful in preparing and recording findings)

iv.        assure proper operation of chemical fume hoods and biological safety cabinets

(b)        Work Practices

i.          policy and procedures

ii.         safe work procedures (written and accessible)

iii.         information available to workers relating to hazards

iv.        accident or injury data and reporting mechanisms

v.         maintenance reports

vi.        training provided

vii.       personal hygiene

viii.      good housekeeping

ix.        proper waste disposal

x.         proper handling, transportation, and restraint of animals

xi.        provision and use of personal protective equipment

(c)        Environment

i.          e.g. noise, lighting, ventilation, thermal conditions

ii.         assure meets all standards and guidelines

(d)        Behavior

i.          determine the effectiveness of systems in place

ii.          identify the need for training and education programs

(3)        The inspection party should ask themselves:

(a)               What is wrong?

(b)               Why is it wrong?

(c)               What if...such and such happened?

4. RECORDING OBSERVATIONS

1.                  Observations made during the inspection must be recorded on the University of Arizona Animal Hazards Program Health and Safety Inspection Checklist and Report Form.  This ensures that issues raised are not forgotten and provides a valuable reference source for spot inspection and periodic checks by supervisors.

2.                  The Identified Hazard Summary Sheet with required signatures must be filed with the IACUC office and a copy kept at the work site to be available to IACUC, granting agency, and AAALAC site visitors.

3.                  New investigators, who have not commenced with animal work, will be allowed to waive the requirement for one year.

5. REVIEW: the inspection team should immediately analyze the report and develop an action plan according to agreed priorities.
    

6.  FOLLOW UP 

1.         The information obtained from regular inspections should be reviewed carefully, not only to identify where immediate corrective action is needed, but also to identify trends as part of overall monitoring of the inspection program’s effectiveness.

2.         Analysis of inspection records over a period of time, for example:

a.         highlights the need for training in certain areas

b.         provides insight as to why accidents are occurring in particular areas

c.         establishes priorities for corrective action

d.         assists in improving or establishing healthy safe work practices

e.         indicates areas, equipment, etc. which may require more detailed hazard analysis

3.         Remember that inspections are only successful in accident prevention if deficiencies receive prompt corrective action.

7. NONCOMPLIANCE/NON-PARTICIPATION

1. Principal Investigators who do not file the University of Arizona Animal Hazards Program identified Hazard Summary Sheet as required:

a.      Will not have subsequent protocol submissions reviewed until such time as the report has been filed.

b.      Will have a hold imposed on all their protocols for animal ordering.

c.      PIs will be allowed an additional two week period to become compliant, or provide acceptable written justification for why they need longer, before all facilities access for their research group (as identified in their protocols as participating personnel) will be deactivated in order that animals already on study will not be wasted.

2. Follow-Up Action: In the event that an individual is found in the facility after having their access withdrawn for being non-compliant, the PI will be required to attend a convened IACUC meeting to discuss this issue.  If a satisfactory conclusion is not arrived at, all the PI’s protocols may be subject to suspension, which would also require notification to the granting agency.

3. Persons will be deemed non-compliant if they refuse to complete a Risk Assessment Questionnaire, or do not file appropriate declination forms. 

In the event that an individual is designated “Non-Compliant” the following actions will be taken:

1. A letter from Occupational Health will be forwarded to the individual, their OSD, or Supervisork and the institutional Animal Care and Use Committee (IACUC) office informing them of the person's non-compliant status..

2. The Institutional Animal Care and Use Committee (IACUC) will review the case and the following consequences may be assessed:

   1. No new or renewal protocols or amendments will be reviewed for that individual.

   2. A hold may be imposed on protocols for animal ordering.

   3. Facility access may be withdrawn.

   4. The individual may be required to attend a convened meeting with the IACUC.

   5. Protocols may be suspended.

4. Non-participation:

1. Non-participation is designated when an individual has filed a declination form indicating their decision not to participate in certain aspects of the program:

   1. Clinic Visit

   2. Obtain recommended immunizations or tests recommended by their animal hazard category.

2. Non-participation is not an option for individuals working with primates, in studies involving potential rabies exposure, or as otherwise mandated by the IACUC or their supervisors.

Table 1.  Examples of Selected Hazards in Animal Facilities 

Potential Risk of	Due to	Examples
Back Injury	Lifting Pushing Twisting Falling	feed bags cage racks restraining large animals slip on wet floor
Hearing Loss	Noise	cage wash areas, dog runs
Electrical Shock	Faulty electrical wiring	water on floor, ungrounded equipment
Puncture Wound	Bite or scratch	unrestrained animal
Needle stick	Injecting or bleeding	improper sharps disposal
Exposure	Allergens	animal hair, dander, serum, animal proteins
	Biohazards	human pathogens, zoonotic agents, latent or introduced
	Chemicals	hazardous materials on test, cleaning or decontaminating materials, acids for cage washers
	Radiation	Research isotopes.  X-ray equipment

     TABLE 2.  Rabies pre-exposure prophylaxis guide – United States, 1999 

*Judgment of relative risk and extra monitoring of vaccination status of laboratory workers is the responsibility of the laboratory supervisor (43).

+Minimum acceptable antibody level is complete virus neutralization at a 1:5 serum dilution by the rapid fluorescent focus inhibition test.  A booster dose should be administered if the titer falls below this level. 

Category of risk is determined by the category of animal contact you have been assigned to and review of the animal protocol you have submitted to IACUC.  Anyone having exposure, or suspected exposure, to a rabies positive animal or tissues; or contact from a suspect animal that cannot be tested, or quarantined, for rabies, will undergo postexposure prophylaxis therapy

It is the responsibility of the OSD to monitor the risk to students, student teachers, and lab workers and obtain the appropriate immunizations for them BEFORE exposure occurs.  If there is any question as to whether someone should be immunized, contact Occupational Health Service.

      Table 3.  Rabies postexposure prophylaxis guide – United States 1999

*During the 10-day observation period, begin postexposure prophylaxis at the first sign of rabies in a dog, cat, or ferret that has bitten someone.  If the animal exhibits clinical signs of rabies, it should be euthanized immediately and tested.

+The animal should be euthanized and tested as soon as possible.  Holding for observation is not recommended.  Discontinue vaccine if immunofluorescence test results of the animal are negative.

         Table 4.  Animal Hazard Program Category Summary Protocol

Category Summary and Basic Occupational Health Care Recommendations (required Immunizations)