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Responding to the Threat of Airborne Contaminant Attacks in the Workplace

Responding to the Threat of Airborne Contaminant Attacks in the Workplace
  • July 10, 2002

In cooperation with the newly formed federal Office of Homeland Security (OHS), the National Institute for Occupational Safety and Health (NIOSH) has published a set of guidelines for the protection of commercial and governmental buildings from terrorist attacks via building ventilation systems. Health care employers which own or lease buildings should be familiar with the information and recommendations contained in “Guidance for Protecting Building Environments from Airborne Chemical, Biological, or Radiological Attack.

To address the workplace vulnerabilities revealed by the anthrax incidents following September 11th, 2001, the guide focuses on identifying practical, “real-world recommendations” for relatively immediate protective action. As a result, building managers now have a model to assist them in developing a comprehensive risk evaluation and response plan. The objective, however, is not to ensure the prevention of fatalities and injuries arising from a deliberate release of chemical, biological, or radiological (CBR) contaminants, which the guide recognizes is an impossible task. Rather, the guide focuses on deterrence through “hardening” strategies designed to transform buildings into less attractive targets. The guide identifies three categories of these deterrents: those that increase the difficulty of introducing a CBR agent into a building's environment; those that increase the opportunity to detect terrorists before they carry out the release of a CBR agent; and those that enhance the opportunity or ability, through mechanical or procedural measures, to mitigate the effect of a CBR release.

The crucial first stage for achieving these deterrents, before any remedial measures are taken, is to “know your building”. Depending upon the actual nature, age, operational requirements, and condition of a particular system, what seems an “obvious” solution may have disastrous results. Therefore, the guide advises building and facility managers to conduct a thorough review of building system design and operation. This process should include a planned walk-through inspection of all relevant systems, starting with the heating, ventilation, and air conditioning (HVAC) system, and including the fire-protection and other life-safety systems.

Once the baseline has been established, the guide offers “specific recommendations,” organized into four general topics:

Things Not To Do. This section provides general guidance as to remedies that will likely do more harm than good, such as permanently sealing outdoor air-intake vents;

Physical Security. This section addresses options for reducing unauthorized access to system features that can be exploited to release CBR agents into a building’s atmosphere. Topics include methods to ensure controlled access to mechanical rooms, practical techniques for relocating or redesigning vents and outlets, and advice for establishing clearly demarcated security zones that increase the conspicuousness of unauthorized persons;

Ventilation and Filtration. This section advises building managers to evaluate mechanical air control systems from two perspectives: first, to identify the extent to which weaknesses in the system contribute to the vulnerability of building occupants; and secondly, to identify feasible means to minimize cross contamination from exposed areas and of means to filter, neutralize, or expel released CBR agents;

Maintenance, Administration, and Training. The final topic addresses (a) incorporation of defined CBR release scenarios into the general emergency response plans for the building’s occupants, including regular practice drills; (b) focused training for HVAC maintenance staff regarding response procedures in case of a CBR release and regarding safety risks to both the building occupants and maintenance personnel; and (c) development of procedures for regular, scheduled maintenance to ensure constant, optimal performance of the HVAC system. The guide recognizes that “physical security is the first layer of defense.” It cautions, however, that reduction of a building’s vulnerability to CBR attack requires a comprehensive approach.

Editor’s Note: Download the complete guide. Copies also may be obtained by mail by requesting NIOSH Publication No. 2002-139 via the agency’s toll free request number (800) 356-4674).

©2002 Jackson Lewis P.C. This material is provided for informational purposes only. It is not intended to constitute legal advice nor does it create a client-lawyer relationship between Jackson Lewis and any recipient. Recipients should consult with counsel before taking any actions based on the information contained within this material. This material may be considered attorney advertising in some jurisdictions. Prior results do not guarantee a similar outcome.

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