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Health and Safety in Canadian Workplaces: Six: Biological Hazards

Health and Safety in Canadian Workplaces
Six: Biological Hazards
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  • Project HomeHealth and Safety in Canadian Workplaces (Second Edition)
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Notes

table of contents
  1. Cover
  2. Acknowledgements
  3. Preface
  4. One: Workplace Injury in Theory and Practice
  5. Two: Legislative Framework of Injury Prevention and Compensation
  6. Three: Hazard Recognition, Assessment, and Control
  7. Four: Physical Hazards
  8. Five: Chemical Hazards
  9. Six: Biological Hazards
  10. Seven: Psycho-social Hazards
  11. Eight: Health Effects of Employment
  12. Nine: Training and Injury Prevention Programs
  13. Ten: Incident Investigation
  14. Eleven: Disability Management and Return to Work
  15. Twelve: The Practice of Health and Safety
  16. Notes
  17. About the Authors

Chapter 6. Biological Hazards

Learning Objectives

After reading this chapter, you will be able to:

  • ➤ Define biological hazards and explain how they affect workers.
  • ➤ Explain how biological hazards can be transmitted to workers.
  • ➤ Assess the positive and negative impact of science on worker safety.
  • ➤ Argue for and against the use of the precautionary principle.
  • ➤ Develop a control strategy for a biological hazard using the location of control approach.

In the spring of 2020, the COVID-19 virus brought biological hazards to the forefront of OHS practitioners’ minds. The largest workplace outbreak in Canada occurred at the Cargill meatpacking plant in High River, Alberta, just south of Calgary. Meatpacking entails the slaughter, dismemberment, and packaging of animals. It is a physically demanding job that exposes workers to numerous physical hazards (e.g., sharp objects, repetitive motions) and biological hazards (e.g., blood, feces, and bacteria).

Approximately 2,000 workers were employed at Cargill, including significant numbers of recent immigrants and migrant workers. Migrant workers are an attractive type of worker for meat-processing employers because their work visas effectively tie them to the employers. This makes them less likely to resist low wages and poor working conditions.1 Like most meat-processing plants, to maximize productivity, Cargill’s plant puts workers in close quarters with each other, often with poor ventilation.

In light of the risk posed by COVID-19, Cargill implemented a series of ultimately ineffective COVID-19 protocols (e.g., more cleaning, altered schedules, banning visitors) while initiating an attendance-based bonus program to incentivize workers to come to work every day.2 The first COVID-19 case at the plant was confirmed on April 6. Cargill refused to hold an emergency meeting of the plant’s joint health and safety committee, provide additional distance between workers, or provide more effective personal protective equipment. It also refused to identify infected workers so that close contacts could take precautions. Instead, Cargill implemented temperature checks and symptom screening upon entry to the plant.

By April 13, there were 38 confirmed cases in the plant. Cargill refused a request by the workers’ union for a two-week shutdown, calling it “inflammatory.” The next day government Occupational Health and Safety (OHS) inspectors, fearing for their own safety, performed a plant inspection via online video and declared it as safe as “reasonably practicable.” Union concerns about the quality of this inspection were ignored. On April 18, government officials, including the chief medical officer of health, held a town hall with workers. They declared the plant safe and urged the workers to continue to go to work, even though the provincial health authority knew that 200 workers at the plant had tested positive. The next day the first worker at Cargill (Niep Bui Nguyen, 67) died from COVID-19. Family members of some Cargill employees also became ill. Some of those family members worked in local long-term-care facilities.

The union, barred from Cargill’s meeting, held its own virtual town hall and informed workers about their right to refuse unsafe work. Over the next 24 hours, hundreds of workers invoked that right (i.e., refused to go to work by citing the imminent danger from COVID-19), and Cargill subsequently announced a two-week shutdown. The plant reopened on May 4, the same date that the government linked over 900 COVID-19 cases to the plant. A second worker (Benito Quesada, 51) at Cargill died because of COVID-19 on May 9. A few days earlier the father of a Cargill worker (Armando Sellegue, 71) had also died.3 Eventually, nearly 1,000 Cargill workers tested positive, and over 600 other cases were linked to these workers, which at the time comprised over 25% of Alberta’s confirmed COVID-19 cases.4

The COVID-19 outbreak at Cargill’s High River plant illustrates the potential harm that uncontrolled biological hazards can cause to workers. It also illustrates again the permeable barrier between occupational health and safety and public health. Biological hazards, such as viruses, can be transmitted both inside and outside the workplace. Preventing the spread of diseases caused by biological hazards often requires controls both in the workplace and in the general population.

A useful historical example is cholera. It is a disease caused by exposure to bacteria, often from drinking water (whether at home or work) contaminated by human feces. Cholera can trigger severe diarrhea (10–20 litres per day), which in turn causes dehydration and electrolyte imbalance. Untreated, the disease can be 50–60% fatal. In the Global North, cholera outbreaks have been largely eliminated through water- and sewage-treatment programs as well as surveillance, sanitation regulations (particularly in the food industry), medical care, and, in some cases, vaccination.5 The principles developed to control diseases such as cholera continue to inform our response to biological hazards.

BIOLOGICAL HAZARDS

As we saw in Chapter 3, biological hazards are organisms or the products of organisms (e.g., tissue, blood, feces) that harm human health. There are three types of organisms that give rise to biological hazards:

  • Bacteria are microscopic organisms that live in soil, water, organic matter, or the bodies of plants and animals. For example, the E. coli bacterium lives in human and animal digestive tracts and some strains can cause food poisoning, infections, or kidney failure when ingested.
  • Viruses are a group of pathogens that cause diseases such as influenza (the “flu”) when they enter our bodies.
  • Fungi are plants that lack chlorophyll, including mushrooms, yeast, and mould. Many fungi contain toxin or produce toxic substances. For example, stachybotrys chartarum (black mould) produces toxins called mycotoxins that cause nausea, fatigue, respiratory and skin problems, and organ damage when the toxic spores are inhaled.

Insect stings and bites, poisonous plants and animals, and allergens are also biological hazards. Box 6.1 examines how climate change is increasing workers’ exposure to biological hazards.

Box 6.1 Impact of climate change on biological hazards

Climate change has altered the biological hazards faced by workers as well as the frequency of their exposure. For example, increased precipitation caused by rising global temperatures can change which plants, animals, and vectors of disease transmission (e.g., insects, rodents, birds) are present in an area. Human responses to environmental disruptions caused by climate change, such as the large-scale migration of individuals and industries, can also introduce new biological hazards to a region.6

Working outdoors often entails contact with insects. They can be biological hazards in themselves if they bite, sting, or burrow as well as potential carriers of diseases. Changes in temperature and moisture can increase the population of insects by making breeding and survival easier. Such changes can also extend the traditional ranges of insects and lengthen the periods of the year during which insects are active. Ticks, for example, are common across Canada and can transmit Lyme and other diseases. Climate change has expanded their range, season of activity, and population density.7

Changes in weather patterns induced by climate change can also create or intensify biological hazards facing workers. For example, higher than normal precipitation can overwhelm drainage systems and contaminate drinking water supplies with bacteria. In contrast, lower than normal precipitation can reduce the quality and availability of water, impeding sanitation practices. Rising temperatures can also aid the growth of temperature-sensitive bacteria, including those that cause cholera.8

Like other kinds of hazards, climate change will require employers to revisit long-standing biological hazard assessments and associated control activities to determine what has changed or might change. Such impacts might be industry specific. Work performed outdoors can put workers at greater risk of encountering biological hazards caused (or worsened) by climate change. That said, work performed primarily indoors, such as health care, can also be affected as workers face greater workplace exposures to climate-sensitive biological hazards.9

As with chemical hazards, the nature of biological hazards highlights that the line between occupational health and safety and public health is blurry and easily crossed. Public health protects the health of a community by offering preventative medicine and health education, controlling communicable diseases, maintaining public sanitation, and monitoring environmental hazards. Because bacteria, viruses, and fungi can move from public spaces and private homes to workplaces, public health measures protect workers. Similarly, OHS measures can affect public health because biological hazards can be carried from workplaces to public spaces and private homes.

Consider the Cargill vignette at the beginning of this chapter. The COVID-19 virus was brought into the plant by someone who contracted it elsewhere. It then spread among the workers in the plant. Those workers took it home, infecting their families. Some of those family members might have taken it into other workplaces, including a local long-term-care facility. This example highlights that biological hazards can be very difficult to control because the boundaries of the workplace are more permeable than is the case with physical hazards.

MECHANISMS OF TRANSMISSION

Like chemical hazards, biological hazards can enter our bodies via respiration, skin absorption, ingestion, and skin penetration. There are three main ways that biological hazards that cause disease, such as bacteria and viruses, are transmitted to workers.10Contact transmission means that a worker is exposed to a pathogen through direct contact with someone or something. Contact transmission can also occur when an individual coughs or sneezes and a droplet of mucus (containing the pathogen) is released into the air. This droplet can transmit the pathogen to a new host. It has been generally assumed that droplets do not travel very far (about one metre) and do not stay suspended in the air for very long. COVID-19 revealed that this assumption is not always true (see Box 6.2).

Some pathogens can be transmitted through food, water, or air. This is called vehicle transmission because the food, water, or air acts as a vehicle for the pathogen. For example, aerosols are fine particles that can float through the air for long periods and over long distances, carrying pathogens from a source to a worker. Hantavirus is found in mouse feces. When dried feces are swept up, the virus clings to particles aerosolized by the sweeping. The aerosols are then inhaled by workers, transmitting the virus to them. As we’ll see from Box 6.2, the distinction between droplet and aerosol transmission is not clear in practice.

Vector transmission refers to a pathogen carried to a new host by an animal. Such transmission can be mechanical, meaning that the vector carries the pathogen without itself being infected. For example, a fly landing on feces can carry bacteria from the feces to your sandwich. When you eat the sandwich, you ingest the bacteria. Vector transmission can also be biological, by which the pathogen reproduces within the vector. For example, immature ticks can acquire Lyme disease by feeding on wildlife. Infected female ticks feeding on human blood then transmit the disease to humans.

Our bodies do have mechanisms by which to cope with some biological hazards. For example, our respiratory system has five layers of defence to prevent harmful particles from entering our body, beginning with the hair-like projections (cilia) on the cells that line our airways (which filter out particles) and ending with cells (macrophages) in the air sacs (alveoli) of our lungs that trap and route impurities into the lymphatic system for disposal. Organisms that enter our body are also subject to attack by our immune system. Yet these mechanisms are not effective against every biological hazard or every exposure.

Box 6.2 COVID-19 mechanism of transmission

Deciding how to control a biological hazard requires an understanding of how workers are exposed to it. For example, if a hazard enters the body through respiration, then control measures need to eliminate (preferred) or mitigate the risk of exposure to the airborne hazard. During the first year of the COVID-19 pandemic, there was significant disagreement about how the virus spread. Unfortunately, an incorrect understanding of transmission was adopted. This error led to ineffective control strategies in workplaces, the unnecessary spread of the virus, and the loss of confidence in public health.

In 2020, both the World Health Organization (WHO) and the US Centers for Disease Control (CDC) asserted that COVID-19 was transmitted through direct contact and by droplets that travelled short distances and persisted in the air for a short time. As a result, public health officials recommended control strategies such as hand washing, surface sanitizing, social distancing, and installing Plexiglas barriers. As it turns out, COVID-19 is spread primarily by aerosols, which the WHO and CDC only later confirmed. Effective control of aerosol transmission entails avoiding indoor spaces, ensuring appropriate air ventilation and filtration, and masking.

The WHO and CDC erred because they were generalizing from dated science that subsequently was misinterpreted. This included using an arbitrary distinction between a droplet and an aerosol and ignoring evidence that droplets stay airborne and travel great distances in real-world conditions. One explanation for this error is that these organizations had to make difficult decisions under conditions of uncertainty, yet this explanation is difficult to accept given that hundreds of scientists wrote to the CDC in 2020 urging it to reconsider its droplet approach.11

In the meantime, COVID-19 continued to spread in workplaces and other public spaces. Most troubling was that the droplet theory became embedded in organizational practices. Even when aerosol spread was acknowledged, organizations did little beyond enacting temporary masking mandates to control aerosol spread.

It took months for the WHO to recommend routine masking in public and a year before aerosol transmission quietly became officially accepted (formal acceptance took place only in mid-2024). At the time of writing (2026), provincial and territorial OHS systems have not taken effective action to control the ongoing aerosol hazard posed by COVID-19.

This delay shows that it can take organizations significant time to evaluate new information. It might also reflect that, once organizations have taken a public position, it can be costly politically for them to alter that position, resulting in organizational foot dragging.

HEALTH EFFECTS OF BIOLOGICAL HAZARDS

Like most workplace hazards, biological hazards can cause both acute and long-term health effects. Acute effects can include immediate or near-immediate injuries, such as allergic reactions and infections. Box 6.3 outlines which workers from which workplaces have been most affected by COVID-19. Biological hazards can also have effects that develop over time. For example, workers who caught COVID-19 sometimes report symptoms long after the acute stage of infection has passed. Other workers report a host of other maladies apparently related to how COVID-19 affects the body’s systems and organs. These maladies include cardiovascular issues (including blood clots and heart attacks), digestive problems, neurological issues, and autoimmune conditions. The ability of workers and employers to recognize and respond to these longer-term effects is impeded by long latency periods, murky causality, and difficulty in observing outcomes.

Box 6.3 Who is affected by COVID-19?

Workers routinely face biological hazards that cause illnesses. This is frequently seen as a normal part of work, particularly for caregivers. It is often difficult to know the prevalence of work-related illness. Workers’ compensation injury claims data are often the most easily available source of information. The key limit (as noted in Chapter 1) is that the data reflect decisions by WCBs about which injuries are reportable and, of those reported, which are compensable. In this way, the data systematically undercount injuries.

Those caveats in mind, the WCB claims that its data are often the best available information and allow us to assess broad trends in work-related injuries and illnesses. Data on COVID-19 claims from British Columbia from February 2023 to January 2024 reveal:

  • Total COVID-19 claims: 22,306
  • Accepted COVID-19 claims: 17,819
  • Most accepted COVID-19 claims by industry: Long-term care (5,832), acute health care (3,865), and public schools (3,063).12

BC data are broadly similar to those reported in other jurisdictions. One important conclusion that we can draw from these data is that claims are concentrated in industries in which significant numbers of people, both workers and others, congregate (schools, hospitals, seniors’ homes) in indoor settings. This suggests that it might be appropriate to concentrate both occupational and public health efforts on controlling transmission in these locations. The data also suggest that most claims originate in highly feminized workplaces, so the short- and long-term injury burden from COVID-19 is likely to be gendered. The gendered nature of COVID-19 is replicated in broader studies of biological hazards; globally, three times as many women die from such hazards as men.13

RISK ANALYSIS AND BIOLOGICAL HAZARDS

Biological hazards are recognized, assessed, and controlled using the HRAC process outlined in Chapter 3, including quantifying the frequency, probability, and consequence of exposure. When assessing the probability of harm, it can be useful to give some thought to the biological agents and the contexts in which workers will encounter them.14 Specifically, we should consider an agent’s stability (e.g., ability to reproduce, resistance to disinfectants) as well as how communicable the agent is and the method by which it can be transmitted. It is also useful to think about the physical infrastructure and existing controls as well as whether the work being performed will intensify the exposure (e.g., cleaning mouse droppings aerosolizes the hantavirus).

Similarly, when assessing the potential consequence of exposure to a biological hazard, it can be useful to consider again the agent, the host, and the potential treatments. Biological agents can vary in their virulence and the severity of the resulting illness as well as the required dose for infection. Some workers might be particularly vulnerable to an agent because of health factors (e.g., a compromised immune system, allergies, age, or pregnancy). Finally, agents can differ in terms of the availability and efficacy of preventative measures (e.g., vaccination) and treatments as well as the required emergency response procedures.

Although risk-assessment tools (e.g., the one in Figure 3.2) can improve risk assessment by forcing us to consider all three dimensions of risk, there is a degree of subjectivity to risk assessment. For example, how serious we rate the potential consequences of a hazard reflects our understanding of the hazard and our own risk tolerance. Box 6.4 examines how the social construction of COVID-19 affected how the public assessed the risk that it posed.

Box 6.4 Social construction of risk from COVID-19

Most workers who have acquired COVID-19 experience a short period of flu-like symptoms. Taking their lead from government messaging, many workers have framed the pandemic as just another endemic disease (e.g., the seasonal flu, a cold). This approach individualizes responsibility for avoiding COVID-19 (i.e., downloads prevention onto workers) and ignores the emerging data on the serious long-term effects of infection on workers’ bodily organs and systems.

It is unclear why governments haven’t taken meaningful steps to eliminate COVID-19, either in workplaces or in society at large. The belief that there is widespread pandemic fatigue among citizens, and that meaningful controls will be unpopular politically, might play a role. It is also worth considering who benefits (at least in the short term) from governments essentially giving up on controlling the spread of the disease.

COVID-19 has posed primarily economic risks for employers. Prolonged business closures during the first year of the pandemic caused significant financial stress for many businesses. Pressure to reopen businesses was one factor in the initial relaxing of COVID-19 protocols. Businesses also faced recurring labour shortages during the pandemic. Some industries, for example, were significantly affected by isolation requirements. In late 2021, airline industry groups and the CEO of Delta Airlines lobbied the CDC to reduce the isolation period for those who tested positive for COVID-19 from 10 days to 5 days in order to reduce flight cancellations because of a lack of crew members.

A few days later the CDC reduced the mandatory isolation period. The CDC justified this change with the claim that most transmissions occurred in the few days immediately before and after an individual tested positive.15 In this view, the economic and social burdens caused by a 10-day isolation period were not worth the small benefits that it conveyed. The timing of the announcement triggered significant skepticism about the real reason for the CDC’s change. Subsequently, research found the CDC’s assertions to be incorrect, with two-thirds of infected persons continuing to be infectious after 5 days.16

In 2024, the CDC further reduced the isolation period to 1 day of being fever-free. This policy appears to have been based on an expectation of population-level immunity (which, after 4 years of the pandemic, clearly did not stop the spread of the disease) and is contrary to the growing evidence of prolonged infectiousness.17 The lack of evidence supporting the change suggests that other factors, such as declining tolerance among companies for isolation, might have driven it. The costs of this change (e.g., heightened levels of illness) will be borne mostly by workers and their families.

SCIENCE AS A DOUBLE-EDGED SWORD

Science plays an important role in both injury prevention and compensation. It has identified hazardous chemical and biological agents, determined the mechanism(s) by which these substances cause harm, assessed the risk of harm, and suggested ways to control hazards and treat injuries. It is important for OHS practitioners to understand how scientific conclusions are reached and the limitations of these conclusions.

The scientific method is a process of formulating, testing, and modifying hypotheses. A scientific hypothesis is a proposed explanation of a phenomenon that can be empirically tested to confirm, refine, or refute this explanation. We conduct measurement, observation, and experimentation to gather data that is compared against the hypothesis. If the data agrees with our hypothesis, we may conclude the hypothesis to be true. However, we cannot be certain the results are not the result of chance or a flaw in the method design. In other words, we need to ensure the results are both valid and reliable. Validity means the results of the experiment or observation accurately reflect the real world. For example, a scale measuring weight is valid if it correctly reports your actual weight. Reliability is the degree to which the results would be consistent if the measurement or observation were performed again. The scale in our example would be reliable if it produced the same result every time you step on it (assuming your weight has not changed).

The questions of validity and reliability plague scientific researchers, and achieving them is a key element of the scientific method. They are particularly challenging for the kinds of research usually associated with OHS-related matters because most of those issues involve human behaviour and physiology. When dealing with humans acting in the real world, there are limits to the control we can achieve over the measurement. It is unethical, for example, to intentionally expose someone to a toxic substance to measure its effects. Also, we cannot identify and control all the possible variables that may affect our results.

As a result, we can never be absolutely certain our results are accurate. As a result, scientists are concerned with false positives and false negatives. A false positive result occurs when we conclude a difference or relationship exists when it does not. False negatives occur when we conclude no difference or relationship exists when it does. Scientists tend to be particularly concerned with false positives because of their potential consequences. For example, saying a drug is effective at treating a disease when it actually is not can harm patients by subjecting them to an ineffective course of treatment. False negatives can also have real-life consequences as they may lead to inaction on health threats. The potentially harmful consequences of false positives means scientists are prone to being very conservative in their conclusions.

Further complicating matters is that most research conducted on OHS matters can only identify a correlation between two variables (e.g., exposure to asbestos and lung cancer). Demonstrating that asbestos (rather than some other, unmeasured, substance) causes lung cancer requires more complex research. The lack of clarity around cause also contributes to scientists’ conservatism around findings. Unclear causation also is used by employers and government agencies, such as WCBs, to deny the harmfulness of a substance and the injury claims associated with exposure to it. For example, smoking also causes lung cancer and so, if an asbestos-exposed worker also smokes, it can be much more difficult for them to demonstrate that their cancer was the result of the asbestos exposure. This is a common issue for workers who develop long-latency diseases.

The reason that scientific practices matter to OHS practitioners is that health and safety is contested terrain. As we saw in Chapter 1, the interests of employers and workers don’t always align. While scientific analysis has been immensely helpful to workers seeking to identify chemical and bio- logical hazards or receive compensation for injuries caused by such hazards, employers can use the conservative culture of scientific research to slow or block worker efforts in these regards. As Box 6.5 shows, employers will often exploit such doubt in an effort to block regulation of hazardous substances.

Box 6.5 Avoiding regulation by manufacturing doubt

Today we know that both vinyl chloride and benzene are dangerous chemicals that affect human health. Vinyl chloride is a polymer used in the production of many plastics, and until the 1970s, it was used in aerosol sprays and other products. Benzene is a component of crude oil that is a powerful industrial solvent and used in production of many products, including nylon. Their dangers were not always widely known.

Debra Davis, a renowned epidemiologist (a scientist studying the patterns and causes of illness and disease in the population), has traced what happened as scientists started to become aware of the health consequences of these chemicals. She found a story of active corporate involvement in the suppression of scientific evidence and discouragement of regulatory controls that she terms “a sophisticated game of scientific hide and seek.”18

These cases draw attention to the strategies employers use to protect their interests in the face of scientific, public, or government pressure for regulation. In both cases, the corporations possessed studies demonstrating the health hazards of the chemicals but refused to allow public access to the results. Insiders trying to get the information into the public’s hand were fired or silenced. Employer strategies in the face of growing public awareness are also illuminating.

To the manufacturing companies, it made sense to fight any effort to restrain production. From the very first reports that vinyl chloride could dissolve the finger bones of workers, cause cancer in animals and deform babies, the industry had a simple response: more research is needed.19

This tactic is aimed at delaying any regulation of the chemical in question. Employers would also sponsor their own research into a substance. In the case of vinyl chloride, employers hired prominent and well-respected scientists such as Sir Richard Doll, considered one of the world’s premiere epidemiologists, whose results downplayed health concerns.

Not until 2000 did it become known that Doll’s efforts on vinyl chloride had not been the independent musings of a disinterested expert. A letter found after his death in 2005 indicated that Doll had served as a consultant to Monsanto [a manufacturer of vinyl chloride] since at least 1979, at a fee of $1,500 a day.20

These efforts are part of a well-documented employer game plan for delaying the recognition of chemical hazards. It starts out with the employer decrying the lack of evidence to substantiate worker concerns about a particular hazard. If the workers have managed to gather evidence to support their claim, employers—sometimes acting through industry associations—will often criticize the methods by which that research was conducted and request additional research, which can cause a multi-year delay in the process. If the employer has generated research that suggests a substance is hazardous, they may prohibit the researchers they contracted to do the research from publishing the results. They may also misrepresent the findings to government or hire a more compliant researcher to create evidence that the substance poses no risk. Finally, when it is no longer possible to deny that a substance is hazardous, the employer may seek to blame the workers for their exposure or argue that continued use of the substance is economically necessary.21

Despite the voluminous research into the hazards of benzene and vinyl chloride, neither has been banned or significantly restricted in industrial processes. OELs have been established, and other safety regulations govern their handling, but thousands of workers continue to be exposed to both chemicals.

The standards set by scientific research can make it very difficult at times to establish that a chemical or biological exposure is hazardous. Employer use of this conservatism can mean that workers can be exposed to hazards with inadequate information about their effects. By contrast, if those regulating chemical and biological hazards adopted the precautionary principle—where the absence of scientific certainty that a substance was hazardous did not preclude regulating potentially hazardous materials or activities associated with it and the burden of proof fell on those advocating its use—it would be much more difficult for employers to resist this regulation. Box 6.6 considers the precautionary principle in more detail.

Box 6.6 Politics and the precautionary principle

The precautionary principle asserts that when a substance is suspected of causing harm to workers, the public, or the environment but there is no scientific consensus on the question, then those seeking to use the substance must prove it is not harmful. In essence, this principle reverses the current evidentiary burden around chemical and biological hazards, which requires critics to prove a substance is harmful before regulation occurs.

The precautionary principle is premised upon the notion that decision makers have a social responsibility to protect workers and the public from harm when there is a plausible case that a substance is harmful. Europe has moved in the direction of the precautionary principle with its Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulations. These regulations place a greater burden on employers and chemical companies to demonstrate that a new chemical is safe, although a number of significant loopholes remain.22 One of the impediments to the adoption of the precautionary principle is that it brings into stark relief and conflict the differing interests of employers and workers around safety. Governments generally prefer to avoid making clear choices between the demands of workers (from whom they derive political legitimacy and electoral support) and the demands of employers (who are economically powerful).

Consequently, governments are reluctant to seriously consider the precautionary principle (which most employers oppose). One outcome of this reluctance (albeit an outcome that is difficult to see) is that employers retain the right to continue exposing workers to substances that are possibly (and even probably) hazardous.

CONTROLLING BIOLOGICAL HAZARDS

As with other workplace hazards, control strategies for biological hazards should be developed with both the mechanism(s) of transmission and the hierarchy of controls in mind. For example, it makes little sense to rely on handwashing to control a virus spread through the air. This approach does not interrupt the mechanism of transmission (i.e., aerosols), and handwashing as a rule (i.e., an administrative control) is subject to frequent failure through non-compliance and error (i.e., not washing thoroughly or long enough).

Successful controls for biological hazards are often so embedded in the world around us that they become effectively invisible. For example, historically, the provision of adequate washing and toilet facilities was an engineering control that significantly reduced worker exposure to many biological hazards. Recent technological improvements, such as automatically flushing toilets and automatic taps, soap dispensers, and towel dispensers, have further limited workers’ contact with bacteria in washrooms. Box 6.7 examines how collective agreements and legislative standards can be employed to control the spread of disease in the workplace.

Box 6.7 Paid sick leave as a control for biological hazards

Typically, hazard control focuses on making changes in the workplace. Government-mandated employment standards can also serve as a form of hazard control. The best way to control a hazard is to eliminate it from the workplace. For diseases transmitted from person to person, whether through direct physical contact or by breathing in aerosolized particles that a sick person has exhaled, excluding those who carry the disease from the workplace can be an effective form of control. In theory, this practice eliminates the pathogen (i.e., the agent that causes the disease) from the workplace, thereby preventing the spread of the disease.

Many Canadian workers must forgo their wages when they call in sick (i.e., they do not have paid sick time). In 2022, approximately 64% of Canadian employees reported having paid sick leave in their jobs. At that time, only Quebec, PEI, and BC required employers to provide paid leave.23 Workers in low-wage, part-time, temporary, and/or non-unionized jobs as well as accommodation, food service, retail, and agricultural jobs were much less likely to report paid sick leave. This aligns broadly with the research set out in Chapter 8 on precarious employment and safety.

Workers without paid sick leave might be reluctant to stay home when sick because they require the wages to pay for the necessities of life. An employer who chooses not to provide paid sick leave externalizes the cost of illness onto workers. This choice minimizes the employer’s labour costs and thereby increases profitability. In this situation, workers might not comply with the employer’s rule to stay home when sick (an administrative control) because they cannot afford the lost wages. Superficially, this non-compliance appears to be the fault of workers. But blaming them ignores how the employer’s decision about compensation incentivizes (and, indeed, might force) workers to go to work when sick.

When employers decide not to provide paid sick leave, the state can mandate it through legislation. In 2023, the federal government legislated a minimum of 10 paid sick days per year for approximately 1 million private sector workers in federally regulated industries. This paid sick leave is the most generous in Canada and reflects the federal government’s experience during COVID-19 that sick workers need to stay home. Most provinces and territories have not implemented any requirement for paid sick time. Those that have typically provide between 1 and 5 days per year.

If the goal of sick leave is to reduce the incidence of illness, then it might also be appropriate to consider leave to care for sick children. Workers unable to stay home to care for their children (or make other arrangements) are frequently left with no choice but to send them to school or other care facilities. This spreads disease, both to the workers who interact with the children and, through other children, to their parents.

The process of developing a control strategy for a biological hazard is essentially the same as for any other hazard. As noted above, it is important to be mindful of the mechanism of transmission such that the control can effectively prevent transmission. It can sometimes be easier to categorize controls for biological hazards using the location of control rather than the hierarchy of controls. As set out in Chapter 3, this approach focuses on where and when the hazard is controlled in the context of where the worker is in the production process. In this approach, hazards can be controlled at three locations:

  • Control at the source addresses the hazard where it first occurs.
  • Control along the path addresses the hazard at some point between its source and when workers encounter it (i.e., it prevents the hazard from reaching the worker).
  • Control at the worker implements controls for the hazard only after it reaches the worker.

If, for example, we seek to control the spread of a virus primarily through the air, then we might consider the following controls:

  • Control at the source: We might limit access to the worksite and test those permitted to be there to eliminate or radically reduce (through the exclusion of carriers) the virus. If an effective vaccination is available, then we might require workers and visitors to receive it. We might even close the office and have workers perform their jobs from home in order to eliminate the virus from the workplace.
  • Control along the path: We might interrupt the transmission of the virus in the workplace through aggressive ventilation and/or air filtration practices.
  • Control at the worker: We might require workers to use PPE (e.g., a high-quality mask) to prevent them from inhaling the virus. We might implement a rule that workers who are ill (or have symptoms) are required to work from home for a period of time or until a condition is met (e.g., a negative test result). If there is a vaccine that reduces the severity of the disease caused by the virus, then we might also offer it (see Box 6.8).

When it is not possible to ensure that a biological hazard has been controlled at the source, it might make sense to implement a series of controls that provides workers with layers of protection. For example, we might increase ventilation, restrict access to the workplace, and require masking and/or vaccination.

Box 6.8 Vaccine effectiveness and resistance

Vaccinations are a control that can be effective against some biological hazards. Public immunization programs during the latter half of the 20th century—focused specifically on vaccinating school children—have largely eliminated diseases such as polio and smallpox. While primarily aimed at controlling disease in the broader population, vaccination programs have also reduced occupational exposures to biological hazards among health-care and child-care workers.

Providing workers with vaccinations is an administrative control that can reduce worker susceptibility to viruses. Vaccines work by imitating an infection, thereby stimulating the body to produce antibodies. These antibodies then allow a vaccinated person’s immune system to recognize and attack the actual pathogen if and when it enters the body. This can prevent infection and/or dramatically reduce the degree of illness that the pathogen causes.24 The effectiveness of immunizations varies. A two-dose course of measles vaccines appears to offer lifetime protection, whereas vaccination against tetanus must be repeated every 10 years. The strength and duration of the immunity generated by a vaccine can vary and be affected by age, medical condition, and medication. In some cases, the evolution of a pathogen can also reduce the effectiveness of vaccination, as is the case with the seasonal flu and COVID-19.

Mandatory vaccinations are controversial.25 One example is influenza vaccination for health-care workers. Although mandatory vaccination is advocated as an important step to protect patients (who can be particularly vulnerable to influenza), opponents note that mandatory vaccination significantly interferes with the right of health-care workers to control their own health and that the annual “flu shot” is only about 60% effective at preventing influenza.26 Some critics assert privately that employers might be more interested in reducing workers’ sick time than protecting patients’ health. This charge should again draw our attention to the potential for financial considerations to affect employers’ OHS practices.

Over time, opposition to vaccination has emerged among the general population. This opposition began with a since-discredited 1998 study that linked autism to the MMR (mumps, measles, and rubella) vaccine. This study was withdrawn after serious misconduct by the scientists who authored the study was uncovered, but in the meantime it contributed to declining vaccination rates in Canada and the United States.27 Fewer immunized children means that child-care workers—95% of whom are women—are increasingly exposed to biological hazards that can cause diseases, such as hepatitis B and measles. Anti-vaccine sentiment intensified during COVID-19, reflecting a combination of misinformation, mistrust, anti-government sentiment, and profiteering by firms offering (largely imaginary) alternatives to vaccination.28

SUMMARY

Biological hazards are often more challenging to recognize, assess, and control. In some cases, they are normalized (e.g., daycare workers get sick) and ignored. In other cases, biological hazards are less readily observed, and the level of complexity involved in their interactions with the human body is greater. Further, health effects may only develop from prolonged exposure, or the disease may have a long latency period. Often, pinpointing the cause of a disease can also be difficult due to exposure to multiple hazards, a lack of knowledge about what we are exposed to in the workplace, and the lack of a clear boundary between work-related and environmental exposures.

As a result, this area of OHS relies heavily on science to understand the effects of biological hazards. Nevertheless, the nature of scientific practices often results in overly conservative conclusions when assessing the risk these hazards pose to workers. Issues with such scientific conventions can be compounded by employers’ long-standing efforts to deny the existence of chemical and biological hazards and avoid taking action to control them. As a result, there is strong evidence suggesting that current protections are inadequate and systematically under-protective of workers. Even if the precautionary principle is not a legal requirement in Canadian workplaces, this dynamic makes a strong argument for adopting the principle for moral reasons when it comes to chemical and biological hazards.

Such an approach would have helped to prevent over 1,000 workplace infections, 600 related infections in the community, and three deaths linked to the Cargill meatpacking plant outbreak in 2020. A popular explanation of the size of the Cargill outbreak is that, in the spring of 2020, COVID-19 was new and poorly understood, and thus the company was operating in uncharted territory. In this view, there was really nothing that it could have done to prevent the outbreak. Yet, in hindsight, we can see that Cargill and the government were presented with many opportunities to limit the outbreak. Yet they prioritized maintaining production over protecting workers’ safety. Subsequent outbreaks at other plants and, indeed, at the same Cargill plant a year later, when much more was known about COVID-19, reinforce the view that such outbreaks were cases of profit trumping safety rather than innocent errors made in novel circumstances.

KEY TERMS

Write a definition for each bold italic word in this chapter.

ACTIVITIES

Triangle icon with the letter 'A' inside.

Select a workplace with which you are familiar and identify a job task performed by a worker that exposes them to a biological hazard. For example, you might select a kitchen at a restaurant or a child-care facility.

Using the HRAC process set out in Chapter 3, perform a hazard assessment for this task. Your completed assessment should include:

  • ➤ A description of the workplace and the work being assessed.
  • ➤ A description of the hazard, which injury it might cause workers, and the mechanism of the injury.
  • ➤ The risk of injury that the hazard poses to the workers, including probability, exposure, and consequences.
  • ➤ Three ways to control the hazard. For each potential control, identify which kind of control it is on the hierarchy of controls, how it would be implemented, and the expected cost and effectiveness of the control.
  • ➤ A recommended control or controls based on your analysis, including a justification for why you recommended this control instead of the other options that you developed.

DISCUSSION QUESTIONS

Briefly discuss with a partner or write 250-word responses to the following questions:

  1. What are the three mechanisms of transmission for biological hazards? Which do you believe you are most likely to encounter in the future?
  2. What would be the most effective control for a highly contagious, aerosolized virus?
  3. Why are biological hazards normalized in the workplace? Who benefits from this normalization, and who bears the costs?
  4. Which specific factors need to be considered while doing a risk assessment for biological hazards?
  5. How does the scientific method both help and hinder the recognition of biological and chemical hazards?

REFLECTION QUESTIONS

Write 250-word responses to the following questions:

  1. What are two biological hazards that you have faced in a workplace? Describe each, including the potential health effects.
  2. Which of these hazards posed the highest risk to you and why?
  3. Did your employer control these hazards? If so, then how? How could your employer have made the work safer?
  4. Do you think that these hazards and the controls that your employer used would have stood up to a worker’s refusing unsafe work?
  5. Which strategies did (or could) you or other workers use to make the work safer?

Annotate

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Seven: Psycho-social Hazards
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