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Animal Care and Management at the National Zoo: Final Report 6 Occupational Health and Safety Programs Organizations are obliged to provide a healthy and safe environment for their workforce and, when public facilities are involved, for visitors. There are many valid ways for an institution to fulfill its commitment to provide a healthy and safe environment. However, the key elements required for developing and sustaining an effective occupational health and safety (OHS) program are a clear directive and consistent guidance from senior staff (NRC, 1997). And a truly successful program depends ultimately on the participation of all employees whose work might affect OHS and visitor safety. REQUIREMENTS FOR OCCUPATIONAL HEALTH AND SAFETY The benefits of an effective worker safety and health program are clear. In general, effective management of such programs have been shown (OSHA, 1989): To reduce the extent and severity of work-related illness and injury. To improve employee morale and productivity. To reduce worker-compensation costs. That is particularly true in the unique setting of a zoo environment. The risks posed by the absence of a comprehensive and effective health and safety program are unacceptable. Evaluations of effective organizations find that exemplary workplaces have common characteristics and similar approaches to OHS programs, including the use of organized and systematic methods (OSHA, 1989): To assign responsibility to managers, supervisors, and employees. To inspect regularly for and control hazards. To orient and train all employees to eliminate or avoid hazards. To identify, evaluate, prevent, and control hazards. To go beyond specific legal requirements. To include a written program describing responsibilities. Consistency is essential to the success of an OHS program, including rules, enforcement, and application to all workers. A lack of consistency can undermine a program. For instance, if higher-level personnel do not adhere to
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Animal Care and Management at the National Zoo: Final Report rules, it sets a bad example. Rules that are too rigid, misunderstood, or considered unreasonable by employees can undermine the credibility of a program (NRC, 1997). Developing programs and policies and then subsequently failing to implement them only fosters cynicism among employees and results in poor adherence to health and safety policies. It is important for management to articulate a clear worksite safety and health policy that: Establishes and communicates clear goals for the OHS. Provides visible top-management involvement in implementing the program. Encourages employee involvement in inspection, hazard analysis, work rules, training, and accident investigation. Provides adequate authority and resources to responsible parties. Holds managers, supervisors, and other employees accountable. Includes periodic program reviews. The following is a brief review of the program elements that must be encompassed in an OHS program at a major zoo (AIHA, 1997; NRC, 1997; OSHA, 1989). It is important to recognize that resources and expertise, in addition to management and employee commitment, are necessary to accomplish these elements. The first element is worksite analysis, which focuses on identifying hazards and anticipating conditions and operations that may lead to harmful occurrences (AIHA, 1997; OSHA, 1989). This process includes Comprehensive baseline and periodic safety and health surveys. Analysis of planned and new facilities, processes, materials, and equipment. Routine job-hazard analyses and site safety and health inspections. Employee notification of management about safety and health concerns without fear of reprisal, and receive timely and appropriate responses to such notifications. Investigation of all accidents and near accidents. Analysis of injury and illness trends (recordkeeping). The second element, hazard prevention and control, includes establishing procedures for the correction and control of hazards by using the hierarchy or control principle (for example, elimination of hazards and engineering controls as a first consideration) and determining the proper use of personal protective equipment. This element also encompasses maintenance, planning and preparing for emergencies, and establishment of an occupational medical program. The third element is safety and health training. Employees must understand the hazards that they will be exposed to and how to prevent harm to themselves. They must also be made aware of what to do in an emergency and how to deal with a potentially harmful exposure. Training should include the responsibilities of all personnel (hourly and salaried), and it is usually most effective if incorporated into other training. It is important for managers to understand their responsibilities and that there is accountability among supervisory staff for carrying out safety and health responsibilities. The occupational health part of a zoo’s OHS program has three purposes: To protect the health of employees and the public. To protect the health of the animal collection. To comply with legal and ethical institutional standards. A number of potentially occupational zoonoses occur in a zoo setting. It is crucial that zoo employees be aware of those risks, know how to protect themselves and to recognize when an exposure has occurred, and have
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Animal Care and Management at the National Zoo: Final Report rapid access to a knowledgeable infectious-disease physician. In a zoo setting, the primary concerns are animal bites and scratches, with injuries associated with cages or other objects, and the resulting risks of such infections as cercopithecine herpesvirus 1 (B-virus) from macaques, Q-fever, toxoplasmosis, tetanus, and rabies. Contact with venomous animals might require emergency access to antivenin. Medical surveillance, serum banking (not currently recommended as a standard component of an OHS program; NRC, 1997), immunizations, worker compensation, hearing conservation, and physical examinations (for example, for respiratory protection programs) are other subjects that should be addressed by a zoo’s occupational health program. A zoo’s OHS program must also deal with animal-escape and animal-restraint issues, including policies, procedures, and exercises; therefore, OHS department personnel are often members of a facility’s institutional animal care and use committee. Visitor safety is an issue that involves the NZP Police Department to a large degree and must be considered and evaluated during all facility modifications and exhibit changes. CURRENT STATE OF OCCUPATIONAL HEALTH AND SAFETY AT THE NATIONAL ZOO Safety Program The zoo safety program is administered by a safety officer and two safety committees that are responsible for safety support of about 450 employees (both the National Zoo and Friends of the National Zoo), the Center for Research and Conservation, and the public (personal communication, J. Hilton, August 28, 2003). The safety committees (one at the Rock Creek Park facility and one at the Front Royal facility) assist the safety officer in coordinating and administering the safety program. The current safety manager appears to be well qualified and knowledgeable regarding Smithsonian policies and procedures, OHS standards, and the principles of managing safety and health programs. He seems to have achieved credibility with employees and management. However, he is not supported by an administrative staff or safety technician. Organizationally, the safety department appears to be positioned appropriately within the management structure as the safety officer reports to the assistant zoo director and attends weekly senior management staff meetings held by the zoo’s director. The Smithsonian Office of Environmental Safety and Health provides audit and oversight functions for the zoo’s safety program through periodic inspections of the zoo’s safety program and procedures. Given appropriate resources and senior management follow through to incorporate training on OHS into a comprehensive training program for animal care staff there is reason for optimism that a comprehensive and effective OHS program will be attained at the zoo. Before the red panda deaths on January 11, 2003, responsibility for pest-control contracts and plans rested with the safety officer, who reported to the facilities department. After the deaths, responsibility for pest control was reassigned to the Department of Pathology. The safety officer currently is responsible for the administration of the safety programs at Rock Creek and Front Royal, safety training, and investigation of accidents. The members of the safety committees are responsible for communicating with the safety officer, holding safety discussions with workers in their area, and conducting routine inspections and training within their function unit. The safety program utilizes training videos and other information, including procedures for animal captures that are available for loan to the various units. Each safety committee has at least one representative from each organizational unit (NZP, General Memorandum No. 100, August 9, 2003). A zoo-wide chemical approval procedure to ensure that all chemicals (including pesticides) are reviewed and approved prior to use was presented to all zoo staff on October 1, 2003 (NZP, General Memorandum No. 125, September, 24, 2003) and has now been fully implemented. In collaboration with the Facility Manager, a form was created that requires approval from multiple persons in order to authorize the application of chemicals anywhere in the zoo complex (NZP, Chemical Approval Form, September 24, 2003). In addition, a chemical inventory database now exists that identifies the location of an application, volume of the application, approval secured, location of a material safety data sheet (MSDS), and the purpose of the chemical (e.g., maintenance, horticulture, pesticide, laboratory, hospital, janitorial). The one component that should be included in the new chemical approval procedure is a purchasing policy requiring that all purchases of chemicals must be made by the Purchasing Department; currently any department can purchase any chemical. In this way the use of chemicals throughout the zoo can be monitored and potential problems with the inappropriate use of a chemical can be mitigated. In addition to chemical control, this policy would help ensure compliance with the OSHA Hazard Communication Standard (29 CFR 1910.1200).
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Animal Care and Management at the National Zoo: Final Report Initially, the safety program staff was operating in a reactive mode rather than proactive mode and daily activities entailed responding to events, emergencies, issues, routine regulatory requirements, etc., as opposed to focusing on the development or enhancement of sustainable programs (personal communication, J. Hilton, August 28, 2003). The safety program has now been able to achieve a better balance between a crisis-management operation of responding to day-to-day issues and a more proactive program-oriented approach. The implementation of the chemical inventory and approval program, hazard communication program, development of policies and procedures, and training of NZP staff was a significant step toward this improvement (personal communication, J. Hilton, March 17). Two animal escape drills have been held, and safety training classes are routinely offered for employees (AZA, 2004; NZP, Spelman letter, February 13, 2004). When specialized expertise is needed on, for example, industrial hygiene monitoring, environmental issues, and safety engineering, the Smithsonian Office of Environmental Safety and Health can provide resources (personal communication, J. Hilton, August 28, 2003). One example of this is the recent Washington DC issue concerning lead in potable water (there are about 6 lead-lined tanks in NZP that were taken out of service and a zoo-wide testing program was implemented), NZP safety staff relied on the Smithsonian Industrial Hygiene and Environmental group as the lead for responding to this concern. The zoo has a formal policy on keeper safety (NZP, General Memorandum No. 11, August 8, 2003), which like many policies was revised in April 2003. Although a 2003 AZA Accreditation Report (AZA, 2003a) noted that documentation of safety procedures was inconsistent within the zoo, a follow-up inspection conducted in February, 2004 found that “significant improvements in these areas have been made” (AZA, 2004). However, the committee continued to observe failures in compliance with written good safety practices. For example, in the primate area, workers were observed feeding the great apes without ready access to a two-way radio (for use in an emergency), because radios were insufficient for all personnel. Also, workers in the primate area do not always conform to professional attire, wearing, for example, open -toe shoes. These behaviors are problematic from a health and safety standpoint and are not in accordance with zoo policy (NZP, General Memorandum No. 11, August 8, 2003). In summary, the safety officer appears to be well accepted by employees and has developed a good working relationship with management from all functional areas. Progress has been made in establishing the necessary programs for ensuring a comprehensive employee and public safety program; however, there are still problems with enforcement of safety policies within some areas of the zoo. Occupational Health Program The zoo operates a health clinic that supports the zoo staff; although not specifically designed for visitors, the clinic also serves the public as necessary (personal communication, S. Striker, August 28, 2003). The clinic is organizationally a component of the Smithsonian Institution, and clinic staff do not report to the zoo administration. It is managed by a registered nurse (a certified occupational health nurse) who reports to the Smithsonian Office of Safety and Environmental Management (personal communication, S. Striker, August 28, 2003). A physician under contract with the Smithsonian is also available to assist with the zoonosis program and with the hearing-protection and respiratory-protection programs. The physician visits the zoo clinic weekly to review records and the status of the programs. Clinic staff track worker accidents and injuries, administer first aid as necessary, support the medical monitoring program, and manage the worker-compensation program. The health clinic is adjacent to the zoo police station. It is below grade and often floods, and there is no patient-bed area or occupational-screening capability (such as audiometry booth or spirometry). Previous access problems (stairs only) have for the most part been addressed by the addition of an elevator that allows nonambulatory patients to get to the clinic (personal communication, S. Striker, March 17, 2004, personal observation); when construction is complete, there should be adequate facilities for disabled, infirm, or injured patients to reach the clinic. The clinic itself is of inadequate size, has only one exit, and is poorly equipped for emergency care (eyewash, shower, and so on). About 100 employees are sent to off-site clinics for spirometry and audiometry exams each year. The current system is both resource-intensive and a disincentive to employees to participate (personal communication, T. Lawford and S. Striker, October 1, 2003). The zoo has considered relocating the Safety and Health Department to the clinic area as part of their long-term planning effort; this would be consistent with modern industrial OHS programs and allow better use of resources, ready access to accident and illness data, trend analysis, medical monitoring programs, and training. However, due to the poor state of the current clinic facilities, other options should be considered. All workers are instructed to notify and report to health services if they experience fever or illness (NZP, General Memorandum No. 105, August 8, 2003). Infectious-disease physicians at Georgetown Medical Center are available for consultation if necessary (personal communication, S. Striker, August 28, 2003). Antivenin is stored
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Animal Care and Management at the National Zoo: Final Report where there are venomous snakes because zoo policy states that if someone is bitten, antivenin is carried with them to the hospital via ambulance (NZP, General Memorandum No. 506, August 8, 2003), as it requires a physician to administer intravenously. Recent “Code Green Drills” for staff and visitor safety were being prepared with snakebite and a macaque bite (B-virus exposure) as themes (personal communication, S. Striker and J. Hilton, March 17, 2004). Zoonosis Program The Zoonosis Program is operated by the Smithsonian and overseen by the Smithsonian Institution occupational physician. It consists of two components, the first of which is the identification and prevention of disease in the zoo’s animals. That is accomplished by using veterinarians, curatorial staff, and animal keepers to examine and immunize animals, quarantine new arrivals, and communicate findings about animal health to the health unit (NZP, General Memorandum No. 500, August 8, 2003). The second component focuses on the prevention of diseases that can be transmitted from zoo animals to people. Zoo employees are screened for infectious diseases, trained on how to avoid infection, and given protection, immunizations, and tests (NZP, General Memorandum No. 500, August 8, 2003). The second component of the Zoonosis Program is the testing and immunization of employees for infectious diseases. There are some formal policies at the zoo on testing and immunization for specific employees (for instance, tuberculosis tests and tetanus shots are mandatory for primate workers) (NZP, General Memorandum No. 500, August 9, 2003). However, the curator of each unit is deciding if an employee should be included in the zoonosis program. This practice runs counter to published texts on occupational health and safety for animal care employees (NRC, 1997; 2003c). The responsibility for performing hazard and exposure assessments for individuals or groups of employees lies with the Safety Department, and with a staff member trained in occupational health and infectious disease, although input from area supervisors is essential. These assessments should identify employees at high risk and identify personal protection equipment vaccinations, and testing that should be provided to each individual to mitigate risk (NRC, 1997; 2003). FINDINGS AND RECOMMENDATIONS Findings: The zoo’s occupational health and safety (OHS) program is operating effectively, although it remains in a reactive mode. Although the OHS program has written policies in place on good safety practices, there has been a lack of compliance with these policies in some areas of the zoo. Testing and immunization requirements of the zoo’s zoonosis program are being determined by unit supervisors rather than by a member of the safety department trained in occupational health and infectious disease. This practice has resulted in inconsistencies in the zoonosis program across zoo units and could lead to some at-risk employees being excluded from the program while other employees are included unnecessarily. The health clinic at the Rock Creek Park facility is not adequate to support the activities of the institution. Recommendations: The zoo’s Safety Department should continue to shift its emphasis toward a more proactive, anticipatory role rather than reacting to events as they occur. Formal written policies pertaining to good safety practice should be enforced and senior management should ensure inclusion of OHS training in a comprehensive training program for animal care staff.
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Animal Care and Management at the National Zoo: Final Report Safety department staff trained in occupational health and infectious disease should determine the testing and immunization requirements for zoo employees based on a hazard and exposure assessment developed with input from unit supervisors.. The Smithsonian Institution must correct the deficiencies in the health clinic facilities at the Rock Creek Park facility.
Representative terms from entire chapter: