Hazardous Biological Agents law on health work

The South African Hazardous Biological Agents law will extend to health work employers, who have to implement a management system by 2017.

Medical and health workers have until April 2017 to implement a comprehensive health and safety management system based on OHSAS 18001.

This follows from the recent inclusion of Class 21 employers under section 7 of the OHS Act. These employers have to develop a formal health and safety policy and system, writes Rudy Maritz.

Class 21 employers cover a large number of small businesses including dentists, medical practitioners, masseurs, radiologists, including nursing staff.

Ambulance associations like St John’s, NetCare, ER24 and others are also included. It also extends to hospitals; maternity or nursing homes and medical research laboratories; and various others exposed to HBA’s from human origin.

It goes beyond exposure to normal biological hazards of human origin, and includes biological agents from animals. Veterinary surgeons, dog breeders, bird fanciers, Pet shops and animal hospitals are also required to comply with this directive.

According to the directive issued by the chief inspector, Tibor Tzana, in Government Gazette 38707 of 24 April 2015, employers in this class must prepare a detailed health and safety policy, including:
• Commitment from senior management to protect, as far as reasonably practicable, its employees and persons other than its employees, from health and safety risks associated with its activities.
• Appropriate to the Occupational Health and Safety hazards and risks of the organisation’s work activities as identified in the facility’s Hazard Identification and Risk Assessment (HIRA).
• Commitment from senior management to comply with the minimum requirements of the relevant OHS legislation, codes of practice and guidelines.
• Commitment from senior management to provide appropriate resources to implement the policy.
• Framework for measuring performance and ensuring continuous improvement by setting, auditing, and reviewing OHS objectives and targets.
• Documented, understood, implemented and maintained at all levels of the organisation.
• Cover employee health and safety representation, health and safety committee meetings and worker participation.
• Provide for employee cooperation and compliance with OHS rules and procedures.
• Available to the community and interested parties.

The notice also states that the HIRA should be detailed and include possible Hazardous Biological Agents (HBA) emanating from the facility’s activities that employees or public might be exposed to at the facility and should cover every aspect of the facility’s process to ensure that all activities at the facility are covered.

While it may be easier for hospitals and large veterinary facilities to comply, the smaller undertakings might find it difficult to achieve this.

According to the directive, the HIRA should include a list of all hazardous biological agents (HBA’s) that employees might be exposed to, and that are defined and listed in the HBA regulations.

The regulations divide HBA’s into four main groups:
a) Group 1; unlikely to cause human disease.
b) Group 2; may cause human disease and be a hazard to exposed persons, but is unlikely to spread to the community and for which effective prophylaxis and treatment is usually available.
c) Group 3; may cause severe human disease, which presents a serious hazard to exposed persons and which may present a risk of spreading to the community, but for which effective prophylaxis and treatment is available.
d) Group 4; causes severe human disease and is a serious hazard to exposed persons and which may present a high risk of spreading to the community, but for which no effective prophylaxis and treatment is available.

The HIRA should therefore focus on Group 4 first, as the highest risk, and work down to group 1 HBA’s.

The regulations also classify HBA’s into three main types: Bacteria, Viruses and Parasites. Generally speaking bacteria are more susceptible to anti-biotic treatments than viruses, putting the former into a lower risk category.

The biggest challenge for the smaller businesses within Class 21, would be to identify which bacteria, viruses and parasites may be present in their operations.

Campylobacter is usually transmitted from domestic animals.
Campylobacter is usually transmitted from domestic animals.

Domestic animals biological risks
The most common human pathogen in domestic animals is Campylobacter spp. This bacteria causes diarrhea, cramping, abdominal pain, and fever within two to five days after exposure to the organism.

Campylobacter is listed as a Group 2 HBA which means that it can spread to the community from exposed employees.

Exposure to Campylobacter comes mainly from faeces when employees are cleaning the cages and disposing of the waste.

Campylobacteriosis usually occurs in single, sporadic cases, but it can also occur in outbreaks, when two or more people become ill from the same source.

Most cases of campylobacteriosis are associated with eating raw or undercooked poultry meat or from cross-contamination of other foods by these items. Outbreaks of Campylobacter have most often been associated with unpasteurized dairy products, contaminated water, poultry, and produce.

Animals can also be infected, and some people get infected from contact with the stool of an ill dog or cat. The organism is not usually spread from one person to another, but this can happen if the infected person is producing a large volume of diarrhea.

Campylobacter is also found in kittens but with cats, one of the most common pathogens is Bartonella spp, also listed as a Group 2 HBA.

Most species of domestic animals including cattle, sheep, chickens, turkeys, pigs, and non-human primates are susceptible to infection.

The USA Centre for Food Security & Public Health has a list of resources to assist in complying with the DOL requirements.
Biological Risk Management

Not all HBA’s are transmitted from animals to humans in the same manner, and the route of transmission needs to be determined to develop an appropriate PPE/C policy. The transfer of HBS’s from animal to human is called Zoonotic Infection and people who have close contact with animals, whether it is pet owners, livestock producers, or animal health providers, can be at increased risk for zoonotic diseases.

Additionally, individuals with weakened immune systems, such as pregnant women, can also be at increased risk. It is helpful to begin a risk assessment by focusing on the routes of transmission:

Aerosol transmission hazard
Most HBA’s do not survive for extended periods of time within the aerosol droplets and as a result, close proximity of infected and susceptible animals is required for disease transmission. The greater the distance between animals, the less likely transmission will occur. Aerosol transmission may occur in a veterinary hospital through close contact of animals and/or humans.

Aerosol transmission may be the most challenging route of transmission to control. Prompt handling and isolation of coughing/sneezing patients will help reduce the spread of potentially infective organisms via aerosol transmission. How animals move through the hospital will also affect aerosol transmission. Crowded reception areas with animals in close proximity will lead to greater exposure.

Density of animals is very important in determining pathogen spread within a veterinary hospital. This is because density influences not only the contact of susceptible with carrier animals; it also influences the airborne pathogen load.

Oral transmission hazard
Oral transmission of disease involves the consumption of pathogenic agents in contaminated feed, water or licking/chewing on contaminated environmental objects. Feed and water contaminated with faeces or urine are frequently the cause of oral transmission of disease agents.

Animal feed can become a potential threat if not handled and stored correctly. Food source outbreaks of gastroenteritis caused by Salmonella have been observed in small animal practice.

Preventing access and contamination by pests including insects (i.e. flies, cockroaches) as well as wildlife, feral cats, birds, and vermin which may urinate, defecate or otherwise introduce disease is an important safeguard.

Direct contact transmission hazard
Direct contact transmission may occur in parking areas or in the waiting room between animals, in the exam room between patient and doctor, in close contact between animals as they move through the hospital, or in livestock pens or chutes in mixed/large animal facilities.

A build up of clients in the waiting areas may increase the potential for direct contact. Scheduling of appointments to reduce overlap or placement of clients into to exam rooms may help reduce direct contact.

Transmission of disease by direct contact requires direct or close approximation between individual animals.

Fomites transmission hazard
Fomite transmission requires an inanimate object to carry a pathogen from one susceptible animal to another. Fomites is the general term used for items like feedbowls, brushes, bedding, water buckets, halters, fences, and each of these inanimate objects may transmit a different HBA or pathogen.

Other culprits are clothing, coveralls, exam smocks, scrubs, neck ties, boots, shoes, and objects that are used or worn when working with animals.
The most important means of controlling transmission by fomite is through proper cleaning and disinfection procedures.

Vector transmission hazards
Vector-borne transmission occurs when an insect acquires a pathogen from one animal and transmits it to another. Fleas, ticks, and mosquitoes are common biological vectors. Fleas infected with Mycoplasma haemophilus, formerly Hemobartonella felis, may transmit bartonellosis to susceptible cats and to humans.

Plague can also be transmitted by fleas from cats or wildlife to humans and other animals. Both Heamophylis and Bartonella spp are listed as a Group 2 HBA.

High Risk Animals
A number of Group 3 HBA’s may cause animal infections, such as Bacillus anthracis, Mycobacterium bovis, Mycobacterium tuberculosis and the West Nile Fever virus. These are mostly found in Cattle and as such puts cattle in a higher risk category.

Other virusses found in animals belong the the Bunyaviridae family listed from group 2 to 4, of which the most common one in Africa is the Rift Valley Fever virus, Phlebovirus (group 3).

RVF is an heamoragic fever transferred to humans by mosquitos and was first diagnosed in Kenya in 1931 by scientists Daubney, Hudson & Garnham where they identified it in sheep and cattle.

Controlling HBA in the veterinary industry
Disease spread by any of these HBA’s can be influenced by many factors including the disease agent involved, the speed and accuracy of a diagnosis, timely use of proper patient isolation, and appropriate cleaning and disinfection.

Most veterinary practices will benefit from improved and updated general hygiene practices. Adherence to standard precautions is the foundation of infectious disease prevention and will help reduce transmission of most infectious/zoonotic diseases.

Standard biological hazard precautions
Special attention must be paid to zoonotic diseases and immune compromised individuals, a vulnerable population. Signage should be posted in restrooms, treatment rooms and hospital wards to remind staff of practices to protect themselves and others.

Hand washing is, and will remain, the most important measure to reduce the risk of transmitting infectious organisms. When and how hands are washed is important. Hand washing signs and stations should be located in areas where animal contact occurs.

Barrier protection (personal protective equipment or PPE) in the form of gloves, masks, protective clothing and respirators used appropriately can reduce the potential disease risk further. Barrier protection must be appropriate for the type of procedure being performed. It must be available and, if not disposable, properly washed and stored in such a way to prevent environmental contamination.

Limiting the number of individuals that come into contact with potentially infectious animals will obviously limit potential spread of disease. In isolation areas, only designated persons should handle animals and their wastes.

Staff HBA Training and Awareness
Staff training on biological risk management is essential, as is a written hospital infection control policy that can be referred to by staff at any time.

Preparation of written infection control policies will serve as a resource for staff and new employees.

Additional educational tools include:
• Newsletter or bulletin
• Videos, CD’s or web-based instruction
• Posted signs or information panels placed around the workplace – standard precautions handout, hand washing signs, etc.
• Employee questions and suggestions, question-answer board, suggestion box, and question period during meetings, etc.
• Mentoring of new employees by experienced employees
• Knowledge testing
• Recognition program – any type of incentive program that rewards employees for reaching BRM goals.

The DOL recommends that Class 21 employers use the Guidelines for the implementation of OHSAS 18001.

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4 thoughts on “Hazardous Biological Agents law on health work

  1. Please can you tell me if the above would also be applicable to a company that does food microbiological testing.


  2. Berlinda the regulations applies to all employers where there is a risk of HBA exposure. However, the article refers to Class 21 employers only, and food labs are not included in this class. I would suggest you study the regulations and determine your exposure before the DOL decides to investigate the Food sector. However, the DOH and Local Environmental Health departments should cover this already.

  3. Informative, however two points which are not included are;
    1) Policing by competent persons to take swabs as a form of compliance testing, and;
    2) No mention of mould fungi and mycotoxins, which form a suitable breeding medium and distribution of bacteria and fungal infections.
    A interesting book, which can be dowloaded in .pdf format, for creating awareness of the dangers of mould fungus, is Mr Bloomfields – The Mysterious World of Mushrooms, Molds, and Mycologists.
    An interesting case to follow is the shutdown of the organ transplant hospital in the USA by the CDC and investigations into deaths which “most likely” could have been caused by fungal respiratory infections.
    Majority of insurance companies do not cover mold fungi related events causing negative health, wellness, and infrastructure impact.
    Look forward to future class action law claims by groups as the awareness grows that illnesses and other related events are not allergy related but mould fungi related.

  4. …. and just before you consider shooting me down, I am just a lay person who has began research into mould fungus and at the same time became aware of the widespread lack of knowledge of the dangers of mould fungi Black mould in bathrooms, etc.
    So this is not academic in expression just me and what I know to date …

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