The spread of the infectious disease COVID-19, caused by the new coronavirus SARS-Cov-2, is accelerating at a rapid pace within the United States. As many organizations have already begun to see the effects on their bottom line, they are seeking answers and solutions to help them maintain market share and protect their workers through this pandemic.
Like any natural disaster that creates fear, new companies emerge claiming to provide “solutions” to kill the virus and provide decontamination services for commercial buildings. The limited information known about this novel coronavirus allows these companies to prey on the fear of people and therefore companies jump at the idea thinking that it will help their cause. The realty of their decision is it could put the company and its occupants at further risk. Choosing a company, with the right certifications, qualifications, and experience with micro biological decontamination could be the difference between a success and failure.
Before planning on using your regular janitorial company or in-house cleaning crew, it is your obligation to know the risks and decide if you want to accept them. If they do not have the proper training, you are putting them, the occupants of the building, and the entire organization at risk. The Center for Disease Control (CDC) has recently issued the following recommendations.
- Develop written policies for worker protection and provide training to ALL cleaning staff prior to disinfecting.
- Have a written respiratory protection plan and train all employees. Included in this plan should be:
- Fit Testing employees with the respirator they are using
- Medical clearance for respirator use
- Proper donning and doffing procedures for respirator use to prevent personal and cross contamination
- Have a written hazard communication plan (HAZCOM Plan) in accordance with OSHA 29 CFR 1910.1200 and provide training to employees on the chemicals used and the dangers associated with them.
- Train and comply with OSHA’s Blood Borne Pathogens standard.
- Properly dispose of regulated waste and PPE
History of How Hurricanes Led to New State Licensing Requirements
After the, 2004 and 2005 hurricane seasons including disastrous storms such as Hurricanes Katrina and Charley, a similar situation happened within the mold decontamination industry. Unqualified companies began providing “mold remediation” on homes and businesses by spraying chemicals on affected building material and other ineffective techniques as well as providing improper drying services. While the mold seemed to be eradicated at first glance on the outside surface, it was festering behind the walls, cabinets, and other areas that could not be detected visually.
After some time, many individuals would start to experience both chronic and acute health effects as a result of the improper bilogical decontamination. Eventually, either by hiring a professional industrial hygienist to inspect or visibly seeing the mold resurface, they would find that they had severe and hidden mold contamination. When attempting to contact the company that performed the initial remediation services, they would often find that the company had essentially disappeared, didn’t have the proper insurance to fix the problem, or had simply gone out of business.
It didn’t take long for some states to begin enacting mold remediation and assessment laws. They now require companies and/or individuals hold a license to perform both mold remediation and mold assessment services. Those companies would have to undergo state approved training and have a college degree in microbiology or related field or have the necessary experience in order to obtain a license. They are also required to have the proper insurance in order to perform these services. If they did not fulfill these requirements and attempted to provide mold services, they risked fines and potential jail time for repeat offenders.
Biological Decontamination Regulations
While mold licensure and procedural standards have never made it to the federal level, biological decontamination, including virus decontamination, has. What are the laws and certifications required to provide virus decontamination? The Occupational Safety and Health Administration (OSHA), has clear guidelines for workers performing these services. The individuals involved in the decontamination of viruses which cause infectious diseases must obtain the proper training in the HAZWOPER guidelines to perform services under emergency circumstances. These guidelines address Chemical, Biological, Radiation, Nuclear, and explosive clean up and decontamination services. Failure to follow these guidelines is strict and could result in fines of $13,500 per person on-site for first-time violations as well as the risk of imprisonment.
This training and the guidelines include items to keep customers, workers, and the surrounding community safe. Its focus includes, but is not limited to:
- On and off-site surveys
- Setting up a job site
- Job Hazard Analysis
- Safety and Hazard Communication Plans
- Exposure levels for chemical, biological, and radiological hazards
- Decontamination procedures
- Respiratory protection programs
- Qualifying the appropriate level of personal protective equipment (PPE)
- Proper donning and doffing of PPE
- Documentation Procedures
- And more
Is HAZWOPER Certification Needed for Virus Decontamination?
To further understand if HAZWOPER training is needed, several questions need to be addressed, such as:
- Do biological decontamination clean-up services require individuals to be HAZWOPER certified?
- What is a declared emergency requiring HAZWOPER certification?
- Do preventative measure, if there is not a confirmed outbreak, require OSHA or HAZWOPER training.
A response from OSHA received September 6th, 2019 helps to clarify the answers to these questions. You may view the letter here, but in summary this letter states:
- Biohazard remediation workers responding to declared emergency with a released hazardous substance (virus) are required to be trained in accordance with the HAZWOPER standard 29 CFR 1910.120(q)(6)
- Workers who complete post-emergency response cleaning after an emergency is declared shall be trained in the HAZWOPER standard 29 CFR 1910.120(q)(11)
- If clean up services are provided to homeowners, business owners, or other entities when an emergency is not declared, then they still need to comply with the OSHA standards that are related to that clean-up.
- Workers that are taking an aggressive role in stopping or controlling biological decontamination shall have at a minimum 24 hours of training according to 29 CFR 1910(q)(6)(iii)
- Workers taking a defensive and non-aggressive role shall have a minimum of 8 hours of training on decontamination and PPE according to 1910.120(q)(6)(ii)
- The declaration of an emergency may be made at the federal, state, local, or individual entity level.
A virus capable of killing 2-5% of the people that it infects is considered a biological threat capable of being immediately dangerous to life or health (IDLH). Effects from exposure to contaminants may be immediate or have delayed and permanent adverse health effects. Therefore, workers should be properly trained and protected with the appropriate personal protective equipment (PPE).
Since this latest outbreak of the novel coronavirus is immediately dangerous to life or health, at least some level of OSHA and HAZWOPER training is necessary. In addition, President Trump has declared a National State of Emergency, confirming the requirements that HAZWOPER training is needed not only to clean up after a confirmed site contamination, but also to provide preventative measures.
Additionally, at the time of this article, the CDC has not yet provided any specific procedures for handling the novel coronavirus. At this time, there is only interim guidance upon which procedures and protocols are based. While it seems likely these are effective, based on their success in dealing with previous and similar viruses, very little is known about this virus at this time and any services performed may not be effective. It is up to the business and the service provider to determine the best course of action for both preventive and response activities while awaiting additional guidance from the CDC.
