The Animal Hazards Program (AHP) is the occupational health program for personnel caring for, or using animals in research or teaching. The purpose of the AHP is to reduce the human health risks associated with the care and use of animals in research or teaching.
Requirements for the AHP
Requirements for an occupational health program for personnel associated with the care and use of animals are found in the Public Health Service Policy on Humane Care and Use of Laboratory Animals. A description of the occupational health program must be included in the Animal Welfare Assurance required by the National Institutes of Health.
The Institutional Animal Care and Use Committee (IACUC) has oversight of the AHP and its implementation. The IACUC makes programmatic decisions based on current occupational health best practices, as recommended by the AHP Committee. The AHP Committee is composed of individuals from various University departments that have expertise in the health risks associated with the care and use of animals. Each unit maintains policies, guidance documents, and standard operating procedures specific to their areas of expertise and responsibility. The AHP functions in deference to unit authority, providing a means of coordination for the complex system.
The Occupational Health Office of the Campus Health Service (CHS) conducts medical surveillance for the AHP, particularly focusing on items 1 and 6 (above). CHS Occupational Health providers use the Risk Assessment Questionnaire (RAQ) as the primary instrument for obtaining information to determine the risk associated with a participant’s animal activities.
The Office of Radiation, Chemical and Biological Safety (ORCBS) administers three specific laboratory compliance programs; radiological, chemical and biohazard safety. Each compliance program is led by a responsible officer or appointed steering committee that grants approval/authorization to those PIs requesting to use regulated hazardous materials under University licensure, registration, permit, or possession. The ORCBS provides all inclusive services that include publishing required program rules, plans and specific procedures, conducting hazard assessments, performing exposure monitoring, routine on-site inspections, incident investigation, spill response assistance, hazard communication signs and labels, and emergency response and training. ORCBS reviews and approves all hazard use listed in IACUC protocols and amendments before work with hazardous materials commences. Worksites are routinely inspected by ORCBS personnel to evaluate and ensure continued compliance.
Risk Management Services (RMS) administers the University's overall risk management effort by providing occupational health and safety services/programs and insurance coverage for property, liability, and workers' compensation. Those enrolled in the animal hazard protection program receive support from RMS regarding occupational injuries/exposures, medical surveillance, hazardous waste, facility air quality, fire safety, emergency response, respiratory protective equipment fit test and training, and ergonomics.
University Animal Care (UAC) provides support for items 2, 3, 4, and 5 (above). University Animal Care (UAC) is responsible for overseeing all animal care, husbandry, and veterinary functions for the University. Animal facilities that house traditional laboratory animal species are under the direct control of UAC.
All groups using animals appoint one participant to serve as the Occupational Safety Designee (OSD). The OSD and the principal investigator (research), instructor (teaching) or facility supervisor (UAC) are responsible for the occupational safety of the participants in their group. Principal investigators, instructors or facility supervisors may serve as OSDs.
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, and/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.
Identified and emerging animal related hazards are evaluated by the appropriate unit determined by the nature of risk. Evaluation may include inspection of work areas, observation of work practices, review of procedures, debriefing of staff, etc..., and result in recommendations for risk mitigation. The AHP Committee is tasked with evaluating the impact of such recommendations to the animal care and use program and fostering discussion to ensure a holistic approach to risk management. All hazard discussions are documented in the AHP Committee meeting highlights and relevant supporting materials are archived with committee files.
Participation in the AHP
Personnel are required to participate in the AHP if they are involved in the direct care of animals, their housing, have direct or environmental contact with live or dead animals, and/or their unfixed tissues, fluids or wastes. This includes UAC staff, animal researchers and instructors teaching course where live animals or their unfixed tissues will be handled. Non-University of Arizona students, consultants, volunteers or visiting scholars who will be performing animal work as defined above may also be required to also participate in the AHP.
The following personnel are exempt from participation in the AHP:
Personnel who only work with fixed or otherwise sterilized animal tissues, fluids or wastes.
Personnel who work solely with commercial animal products, such as organs, tissues, cells, or antibodies.
Protocol participants with no contact with animals, tissues, fluids or wastes, and who do not enter animal areas may sign an exemption statement on the RAQ. Typically, these participants are administrative personnel.
In order to decline any or all of the medical services offered by the AHP, participants must submit a RAQ. CHS Occupational Health will review the RAQ and determine whether declination is an option based on the animal activities. For certain, immunizations, diagnostic tests and/or personal protective equipment are required and cannot be declined.
Personnel choosing to decline full participation in the AHP must sign the Medical Surveillance Program Declination form documenting an understanding of the risk associated with their declination.
The IACUC, OSD or principal investigator, instructor or supervisor will be notified of all declinations. The principal investigator, instructor or supervisor and/or OSD will further determine if the declination places the participant at increased risk of illness or injury and will address this with the participant as it relates to performance of their work.
Basic Occupational Health Care Requirements
The Basic Occupational Health Care (BOHC) requirements are based on current occupational health recommendations and best practices identified from a number of sources and are used to reduce the health risks associated with specific animal activities. The BOHC requirements are reviewed at least every six months by the AHP Committee. Recommended changes are reviewed and approved by the IACUC prior to implementation.
Medical Evaluation and Preventative Medicine
After reviewing the RAQ, and in accordance with the BOHC requirements, the CHS Occupational Health provider may require a clinic visit. The clinic visit is used to further determine the need for immunizations, diagnostic tests and/or personal protective equipment. Participants may provide documentation of current immunization status in lieu of immunization. The clinic visit and/or any of the recommendation made by the provider may be declined, as described above.
Participants may be referred to other worker protection programs administered by Risk Management Services. For example, participants at increased risk for developing work related allergies may be referred to the Respiratory Protection Program.
Participants will be periodically recalled for medical follow-up depending on the specific type of animal exposure and the BOHC requirements. Medical recall may be declined, as described above.
Monitoring of Animal Use Facilities for Hazards
The Animal Hazards Checklist (AHC) is a mechanism to identify hazards in areas where animal activities occur. Different checklists apply to various animal use locations. Locations must be inspected by the OSD at least every six months and the results documented in the AHC. The principal investigator, instructor or supervisor and OSD are responsible for ensuring that identified hazards are rectified in a timely manner. The IACUC reviews the AHC during submission of the Annual Status Report and/or the semi-annual facility inspection.
Non-Compliance with AHP Requirements
Non-compliance with any portion of the AHP is referred to the IACUC for review and determination of appropriate action. Actions may include denial of UAC access, revocation of approval to participate in an animal activity, protocol suspension and/or reporting to federal agencies.