ShelterSpeak: Employee Safety
"I’m just curious as to how many shelters require their employees to wear rubber gloves, protective eye wear, and even earplugs or something comparable to block out loud noise (barking) in the dog kennel area when cleaning/feeding? Is this truly a requirement, and if not, should it be? I’m wondering, too, if the earplugs fall under some type of OSHA [Occupational Safety and Health Administration] regulation for auditory protection?”
—Lori Mikajlo, manager, Somerset Regional Animal Shelter, New Jersey
Susan Asher, executive director, Nevada Humane Society
I do require that my kennel staff use protective ear wear in the kennels, particularly when all the dogs are locked inside (we have indoor/outdoor kennels), as the first feeding begins and as the outside runs are being cleaned.
OSHA did come through upon my request for a voluntary inspection several years ago and the decibel level registered 110—airport runway strength! While the inspector did not make wearing ear protection a requirement in his report, he strongly recommended it. (On the lighter side, he also had a nervous breakdown when he saw that office staff drank coffee at their desks—and, God, there are CATS IN THE OFFICE! I reminded him that this was a humane society and that animals were a fact of life here. That, in fact, we all would suffer if we did not receive our daily allowance of ingested cat or dog fur.)
However, when the guillotine doors open, the sound dissipates and the need to wear the earmuffs or earplugs diminishes. We make gloves, goggles, back supports, and other protective gear available to staff for various functions, but unless the staff is dealing with zoonotic disease issues, I do not make all of it mandatory. For instance, some staff members prefer to wear goggles while performing euthanasia, because they have blown a syringe into their eyes in the past (I always seem to get it in my mouth). But as the level of experience grows, the need is less urgent. Latex gloves are seen as a detriment to the sense of touch required to locate that vein, feel that heartbeat, etc. But in our spay/neuter clinic, that protocol is completely different and falls under the direction of the vet in charge. Whatever she says goes.
Most of our occupational injuries occur from trips over hosing, cat scratches, and cat bites. My kennel manager did get fitted for wrist braces after 15 years of spraying the kennels down; she was actually developing a carpal tunnel problem with that up/down repetitive motion. As part of our monthly department head meeting, we have a regular safety meeting where the managers have an opportunity to discuss improvements and changes to our safety protocols—or to point out problems. And we very clearly spelled it out in our Employee Handbook that ALL employees are required to report safety hazards, injuries (however minor), or concerns to their immediate supervisors, to my administrative assistant, or to me, without fear of repercussion.
Nicky Ratliff, executive director, Humane Society of Carroll County
I believe every organization owes its employees a safe working environment. My employees have every tool and item I can find to make them safe wherever they perform their jobs. All my computer workstations are 100% ergonomically correct; every kennel employee has protective gloves, slip-resistant rubber boots, eye protection, etc., to be used when needed. If they requested ear protection, it would be provided immediately, but our kennels are not that noisy. All of my ACOs have various types of gloves, face shields, eye protection, hard hats, strap-on ice spikes to be put over their boots, pepper spray, bite sticks, fireman's boots, life vests, attack sleeves, laser flashers for their belts or coats, orange reflector vests, etc., in each of their vans.
Ear protection is not required by OSHA unless the employee is exposed to an average of 90 decibels over an eight-hour period, and employees cannot be subjected to a single blast of 140 decibels without ear protection. If you are unsure, you can hook a noise dosimeter to their belts and place the microphone on their collars, and it will record and measure their daily exposure.
You might want to have a safety analyst come to your facility and offer suggestions.
Christie Smith, executive director, Potter League for Animals
Newport, Rhode Island
Ah ... the dreaded OSHA questions. Everyone in the animal care and control profession should make an effort to better understand OSHA requirements. Not only is compliance required of employers, but it just makes sense to do everything we can to protect our most valuable assets—our employees and volunteers. The Occupational Safety and Health Act of 1970 is terribly misunderstood and often ignored completely in animal shelters.
While the details of OSHA are far too many and complex to address in this short column, there are several basic points to remember. We need to develop and implement a Written Hazard Communication Program that includes the proper labeling of containers, maintenance of Material Safety Data Sheets (MSDS), and training programs that address the safe use of the chemicals in our shelters. An Injury and Illness Prevention Program that includes inspections of our shelters and strong organizational policies, work procedures, and disciplinary actions is also important to ensuring safe and healthy practices. And we need to develop Safety and Health Training Programs to communicate all of this to our employees and volunteers.
Good safety planning will cover everything from installing fire extinguishers to creating first aid kits to developing evacuation plans to posting OSHA posters to keeping records to providing personal protective equipment (PPE). In the work we do, some of the biggest issues faced include wet floors; handling dangerous/vicious/feral/fractious animals; heavy lifting; euthanasia and other veterinary practices; decapitation of rabies-suspect animals; the use of various chemicals and equipment; and noise.
More than likely, ear protection, eye protection, and gloves are necessary at some time during the average shelter workday. Specifically, noise becomes a concern when the level is 85 decibels over an eight-hour period, and constant ear protection is necessary when the decibel level reaches 110. To help develop programs to meet OSHA requirements, check with your workers' compensation insurance carrier, private consultants, the Internet, or OSHA itself.
It is not enough to do the good work of taking care of animals. We need to take care of our people as well.
Eric Blow, director, Jefferson County Animal Control and Protection
We do not have a shelter protocol that requires the use of safety gear for general husbandry duties. We do recommend the use of gloves and masks in certain situations, and we make them available. We require the use of goggles and heavy gloves when handling disinfectants and cleansers.
Deanna Groves, PHR, human resources manager, Denver Dumb Friends League Denver, Colorado
The Dumb Friends League has had its noise levels tested, and we are borderline to falling under OSHA limits. So we provide earplugs (the little foam disposable ones) to anyone who wants them, and we strongly encourage but do not mandate their use. Most kennel techs wear them gladly. We require the use of safety goggles/glasses when performing euthanasia or surgeries. It is an OSHA requirement to do so when there's the potential for chemical or biohazard splash. We encourage use of the glasses/goggles during cleaning, as quaternary ammonium burns in the eye are very nasty.
We require skid-resistant shoes for all operations staff (who are regularly in the kennels) to prevent slip-and-falls.
Jane McCall, executive director, Dubuque Humane Society Dubuque, Iowa
The Dubuque Humane Society requires the use of gloves and safety glasses during kennel cleaning. Our kennels are indoor/outdoor, and we let the dogs outside while cleaning the inside kennels—and inside while we clean the outside kennels—so it's not too loud. We keep ear protection at the kennel door (little plastic plugs or larger ear muffs) for employees to use during afternoon feeding. We also keep a box of little earplugs to offer to the general public when they go inside the kennels to look at dogs. It is strongly suggested by signage that both employees and the public use the ear protection.
Bill Garrett, executive director, Atlanta Humane Society, Atlanta, Georgia
Shelters should issue the following to all kennel staff: earplugs (soft) for ear protection; boots (rubber) for foot protection and infection control; gloves (acid-resistant neoprene) for cleaning of cages and handling and mixing cleaners; and goggles (shatter-resistant wraparounds) for hosing and for prevention of injuries that could be caused if chemical cleaners splash back toward the face.
We issue these items to staff as appropriate. We are going to issue earplugs (cheapos) to all staff and make them available for volunteers, as our kennels are loud. Also, shelters should post all Material Safety Data Sheets near their cleaning supplies; this should be required reading for employees, depending on the circumstances.
It is sometimes hard to enforce safety rules; people often fail to use equipment even when it's available and they're instructed to do so. People aren't bad; they just forget, especially when it comes to ear protection.
In compliance with Occupational Safety & Health Administration regulations, manufacturers or distributors of hazardous chemicals must create Material Safety Data Sheets (MSDS). These sheets are designed to ensure that chemicals are evaluated and that employees are aware of the potential dangers and methods of protection. MSDS detail proper procedures for working with chemicals and substances by describing physical properties, toxicology, health effects, first aid, storage requirements, necessary protective equipment, and spill/leak protocols. To learn more about MSDS and to find other safety-related resources, check out the following Web sites:
MSDS Online: http://www.msdsonline.com
Vermont safety Information Resources, Inc.: http://hazard.com
National Institute for Occupational Safety and Health: http://www.cdc.gov/niosh
National Institutes of Health: http://ntp-db.niehs.nih.gov
Occupational Safety and Health Administration: http://www.osha.gov