REPORT OF
THE GENERAL COUNSEL
OF THE
OFFICE OF COMPLIANCE
U.S. CONGRESS
Investigation of the Health
Effects of Irradiated Mail
Case Nos. OSH-0201, 0202
Gary Green
General Counsel
Michael R. Lemov
Senior Counsel
Cheryl Polydor
Mary Masulla
Attorneys
Stephen Mallinger
Industrial Hygienist
July 2, 2002
Executive Summary
The irradiation of Congressional mail beginning
in November 2001 followed the detection of anthrax spores in 16
Congressional offices. It represented the first use of the irradiation
process to eradicate anthrax spores from the mail delivery system.
Beginning in January 2002, when the United States Postal Service
began delivering irradiated mail to Congressional offices, the Office
of Compliance became aware of numerous employee complaints of adverse
health symptoms apparently caused by contact with irradiated mail,
including headaches, nausea, nose bleeds, rashes, eye and skin irritation
and similar symptoms.
In February 2002, Senator Charles Grassley and
two House of Representatives employees filed Requests for Inspection
with the General Counsel of the Office of Compliance, seeking an
investigation of the possible adverse health effects of irradiated
mail, and the related decontamination of the Hart Senate Office
Building. The General Counsel initiated an investigation based upon
receipt of these requests. The General Counsel's investigation consisted
of review of a redacted version of a report prepared for the House/Senate
Legislative Mail Task Force by the National Institutes of Occupational
Safety and Health ("NIOSH"); consultation with Dr. Laura
Welch, Chief of the Section of Occupational and Environmental Medicine,
Washington Hospital Center; Dr. Clifford Mitchell, Director, Occupational
Medicine Program, Johns Hopkins University; the staff of the Occupational
Safety and Health Administration ("OSHA") and the OSHA
Salt Lake Technical Center. Additionally, we obtained information
and assistance from the Library of Congress Health Services Office,
the Attending Physician of the Capitol and officials of the U.S.
Postal Service.
Our inspection team also conducted its own sampling
of the chemical by-products of irradiated mail, both on Capitol
Hill and at the U.S. Postal Service facilities where mail is irradiated
and prepared for delivery to Congressional offices. Finally, the
General Counsel conducted a survey of potentially affected employees,
including review of two hundred fifteen (215) Contact Sheets provided
to us by affected employees; a telephone survey; a re-survey reaching
a majority of those employees, providing us with updated information;
and evaluation of eighty-one (81) detailed medical questionnaires
completed by employees at our request.
Our re-survey, conducted in May 2002, approximately
three months after the original incidents, found that fifty-five
(55) per cent of the employees who originally reported symptoms
associated with irradiated mail continued to have symptoms. The
symptoms were often milder, but they nonetheless persisted.
The General Counsel has concluded that handling
irradiated mail for substantial periods of time may be the cause,
or a contributing cause, of adverse health symptoms reported by
a significant number of Legislative Branch employees. However, we
do not have sufficient information at this time to reach any final
conclusion on the specific cause or causes of such symptoms, or
whether there is a serious health risk from extended periods of
mail handling under existing working conditions. The accompanying
report provides a detailed account of the progress of our investigation,
as well as recommendations for certain additional studies of the
mail, and interim precautions to limit employee exposure to irradiated
mail pending completion of the additional studies. The Office of
the General Counsel will report further on this investigation as
we develop additional information.
I. Introduction
Delivery of mail to the Congress was suspended
for almost three months, from October 2001 to January 2002, due
to the detection of anthrax spores in 16 congressional offices.
Before resuming delivery of the mail to Congress in January 2002,
the United States Postal Service developed and implemented a new
method to disinfect potentially contaminated mail through the use
of large doses of irradiation. While irradiation had been successfully
utilized for many years to disinfect food and medical devices, the
irradiation of Congressional mail represented the first use of the
process for the purpose of eradicating anthrax spores in the mail
delivery system. This is the first time a large group of employees
is being exposed to irradiated mail on a regular basis.
Shortly after the resumption of mail delivery
to Congress, the Office of Compliance became aware of many employee
complaints of adverse health symptoms apparently caused by irradiated
mail. These included headaches, nausea, nose bleeds, rashes, itching
skin and similar symptoms. This diversity of symptoms is typical
in an occupational health investigation since individual employees
have differing medical backgrounds.
We initiated a full investigation in an attempt
to determine the health and safety effects of handling irradiated
mail. Ultimately, we received over 215 documented reports of symptoms
from employees of the Legislative Branch. We tested for the chemical
by-products of irradiation, using the most effective equipment available.
We considered other possible factors that could explain the reported
symptoms. We consulted with other knowledgeable government agencies
and retained the services of leading medical experts in occupational
health and safety. This report represents our interim response to
employers and employees of the Congress and other agencies regarding
the safety of working with irradiated mail. It also represents,
in part, the implementation of our responsibility under the Congressional
Accountability Act to ensure a safe workplace for employees of the
Legislative Branch.
* * *
The Congressional Accountability Act, passed
by Congress in 1995, directs the General Counsel of the Office of
Compliance (the "General Counsel") to inspect and investigate
places of employment within the Legislative Branch upon written
request of any covered employee or employing office. 2 U.S.C. 1341(c)(1).
The General Counsel is given virtually the same investigative powers
as the Secretary of Labor under the Occupational Safety and Health
Act of 1970, (29 U.S.C. 657, "OSH Act"). The OSH Act,
as incorporated in the CAA, thus affords all Legislative Branch
employees the right to "...a place of employment free from
recognized hazards that are causing or likely to cause death or
serious physical harm to employees." OSH Act 29 U.S.C. 654(a)(1).
II. Requests for Safety and Health Inspection
of Irradiated Mail
The General Counsel received requests for inspection
regarding the health effects of handling irradiated mail on February
6, and February 26, 2002, from two House of Representative employees.
The first employee's request form stated:
...the irradiated mail has been causing illnesses
of Capitol Hill workers who open or handle large amounts of irradiated
mail (illnesses range from feeling lightheaded, bleeding nose
and ears, headaches, stomach aches, itchy skin/eyes and the like).
The second request stated:
Since the second week of January when the mail
came in large quantities, I have been feeling symptoms of itchy
eyes, sneezing, itchy skin, nausea, headaches and sinus congestion.
After...I no longer had to open the mail my symptoms have not
reappeared.
On February 11, 2002, the General Counsel received
a request for inspection from Senator Charles E. Grassley stating:
As you know, at least 73 employees have reported
symptoms such as headaches, skin rashes, dry mouth and eye irritation
after handling irradiated mail. Also, between 50 and 60 employees
in the Hart building have complained of dry eyes, dry throat and
headaches.
A copy of the Senator Grassley's letter dated
February 11, 2002 is Attachment A to this status report. In his
inspection request, Senator Grassley included concerns about the
possible adverse effects of the Hart Building decontamination process,
in addition to irradiated mail. This report primarily addresses
the status of our study of irradiated mail. The Hart Building investigation
is discussed in Section V of our report.
III. General Counsel's Investigation.
Background
At the commencement of the investigation required
by the Congressional Accountability Act, the General Counsel contacted
the Sergeant at Arms of the Senate and the Chief Administrative
Officer of the House of Representatives to obtain any information
relevant to the Requests for Inspection. The Sergeant at Arms of
the Senate stated that he had established a Legislative Mail Task
Force, which was investigating the mail problem. The Task Force
includes representatives from the Centers for Disease Control, Environmental
Protection Agency, National Institutes of Occupational Safety and
Health (NIOSH) and other agencies. The Sergeant at Arms informed
us that NIOSH was, at the request of the Task Force, preparing a
report that would be shared with the Office of Compliance upon its
completion.
NIOSH Report
The NIOSH report was released publicly on April
23, 2002 by the Legislative Mail Task Force in redacted form. It
was furnished to the Office of Compliance in redacted form on the
same day. NIOSH stated that on February 13, 14 and 15, 2002 it had
measured the air in ten (10) Capitol Hill buildings for contaminants
that could potentially come from irradiated mail. These were listed
as carbon monoxide, volatile organic compounds, formaldehyde, ozone,
polynuclear aromatic hydrocarbons, toluene, small particulate and
total particulate. NIOSH also measured typical indoor air parameters
such as carbon dioxide, temperature and relative humidity. NIOSH
found that the sampled substances either were not detected, or were
found at low levels, below those known to cause health problems.
We do not know whether NIOSH tested for other potential chemical
irritants which are by-products of irradiated mail. NIOSH reported
that it interviewed 389 Legislative Branch employees regarding symptoms
they were experiencing in connection with handling irradiated mail.
The most commonly reported employee symptoms were headache, skin
irritation, eye irritation, skin rash, dry hands, nausea and nose
or throat irritation.
NIOSH concluded "...it is likely that multiple
factors are responsible for the reported symptoms." See
NIOSH Health Hazard Evaluation - Irradiated Mail Handling
(April 2, 2002 at 34). NIOSH described the likely causal factors
as:
- damage to the paper resulting from the irradiation
process, which could account for the dry skin and skin irritation
symptoms reported by employees
- odors which can trigger symptoms in some
individuals
heightened awareness and resultant employee stress from recent
terrorist attacks.
- The NIOSH report summary stated: "We
did not find evidence suggesting the potential for long-term health
effects from handling of irradiated mail."
Library of Congress Survey
We also worked with the Library of Congress in
the design of an environmental and health study of Library employees
handling irradiated mail. The Library requested volunteers for this
study. One hundred and forty (140) employees volunteered for a base
line survey prior to receipt of any irradiated mail. The Library
utilized as a base-line a medical examination including pulmonary,
blood and EKG tests as well as a survey questionnaire. The Library
also conducted follow-up examinations of approximately 110 employees
subsequent to the initiation of mail delivery to the Library. Library
officials have advised us that they have not completed their survey.
Preliminary results indicate that the number of complaints which
appear to be related to the handling of irradiated mail has declined
in the last several weeks, but that further investigation may be
warranted. We are appreciative of the cooperation of the Library
and Dr. Sandra Charles, Director of Health Services. We look forward
to receiving the results of the survey from the Library.
* * *
In conducting our own investigation, we carefully
reviewed the NIOSH report. We conducted interviews with the agencies
and officials involved, sampled air quality and potential dermal
effects of handling irradiated mail and consulted with leading experts
in the field of occupational and environmental health and safety.
We consulted with Dr. Laura Welch, Chief of the Section of Occupational
and Environmental Medicine, Washington Hospital Center; Dr. Clifford
Mitchell Director, Occupational Medicine Program, Division of Occupational
Health, Johns Hopkins University; the staff of the Occupational
Safety and Health Administration and the staff of the OSHA Salt
Lake Technical Center. We also met or spoke with the Attending Physician
of the Capitol, the Library of Congress Health Services Office and
officials of the U.S. Postal Service. We also completed our own
survey of potentially affected employees.
Office of Compliance - Legislative Branch
Employee Survey
Within a day of our receipt of the first Request
for Inspection, the Office of Compliance posted on its website,
at www.compliance.gov, a Contact Information Sheet seeking relevant
information from other affected employees. Then, beginning in February
and continuing through March 2002, we sent directly, by internal
mail, approximately 14,000 Contact Information Sheets to all House
and Senate employees and all employing offices, including House
and Senate Committees. The Contact Sheets were also sent to other
instrumentalities of the Legislative Branch. A copy of the Contact
Information Sheet, with the General Counsel's February 21, 2002
explanatory memorandum printed on the reverse side, is Attachment
B to this report.
Two hundred fifteen (215) Legislative Branch
employees responded by completing and submitting Contact Information
Sheets. Many of these employees were thereafter contacted by telephone
to obtain their answers to a more detailed survey regarding symptoms
and working conditions. One hundred forty-eight (148) employees
responded to this telephone survey. Many responders indicated that
they were responding on behalf of several employees in a particular
office, rather than a single employee. In addition, we noted in
our survey a general reluctance by Legislative Branch employees
to complain about working conditions and difficulties encountered
in performing their assignments. Employees of the Legislative Branch
appear to be motivated by loyalty and commitment to their employers
and the institution. In light of these observations, the number
of Contact Information Sheets we received was substantial. Finally,
as we prepared to release this report, we conducted a re-survey
of the employees who initially responded, and reached one hundred
sixty-eight (168) employees with follow-up questions during May
2002.
We received completed Contact Information Sheets
from House staff members representing 90 House member's offices
and 15 committees, and 67 Contact Information Sheets from Senate
employees, representing 34 individual Senate offices and 13 committees.
Eight Contact Information Sheets were returned by employees of other
entities such as the Architect of the Capitol, the Senate Post Office
and the Chief Administrative Office of the House. Those submitting
completed questionnaires were advised that their identities would
remain confidential and that only summary data would be released
publicly.
The Contact Information Sheet and subsequent
responses from our telephone survey, furnished the following information
regarding symptoms experienced by the 215 responding employees.
Many employees experienced multiple symptoms:
- 51% experienced headaches when handling mail
- 32% stated they had itching skin
- 23% experienced burning and red eyes
- 21% experienced nausea
- 15% indicated that they developed a visible
rash
- 11% said that they are now getting bloody
noses and did not have them before handling irradiated mail
In the follow-up telephone survey conducted
in March and April 2002 we reached 148 employees who had sent us
Contact Information Sheets:
- 72% of the respondents reported that
they were still experiencing symptoms.
- 37% of these respondents said that symptoms
were experienced when they were handling mail and not otherwise.
- 25% of these respondents said the symptoms
were getting better.
- 3% of these said the situation was getting
worse.
- 35% of these said the situation was the
same.
- 28% of the respondents reported that
they no longer were experiencing symptoms
- 25% of them said they no longer handle
mail, usually due to an adverse health reaction.
- 42% of these said they still handle mail
but are now symptom-free.
Medical Questionnaire
We also prepared a confidential medical questionnaire
which we asked the respondents to our original survey to complete.
To date, a total of 83 medical questionnaires have been completed
and returned.
The primary information furnished by the medical
questionnaire responses may be summarized as follows.
Eighty-three (83) people completed the medical
questionnaire. The median date on which the questionnaires were
filled out is March 15, 2002, with the earliest date being February
28, 2002, and the latest May 21, 2002.
Eighty-one (81) of the 83 respondents said that
they handle the mail. Seventy (70) of the respondents said that
they opened the mail.
The 81 respondents who handle mail were asked
if they had experienced any of 24 symptoms in the past four weeks.
Of these symptoms, there were eight that had occurred for at least
60% of the respondents. These are:
- Headaches (86%)
- Pain/Stiffness in the back/shoulders/neck
(75%)
- Dry/Itching/Irritated eyes (72%)
- Sneezing (69%)
- Tired/Strained eyes (73%)
- Stuffy/Runny nose or sinus congestion (65%)
- Dry/Burning/Itching skin (64%)
- Sore/Dry/Irritated throat (63%)
The 81 respondents were then asked if these same
symptoms were better, worse or the same when at home. For these
eight primary symptoms, the percentage of people that said their
symptoms got better while at home are:
- Headaches (77%)
- Pain/Stiffness in the back/shoulders/neck
(45%)
- Dry/Itching/Irritated eyes (92%)
- Tired/Strained eyes (66%)
- Sneezing (60%)
- Stuffy/Runny nose or sinus congestion (54%)
- Sore/Dry/Irritated throat (65%)
- Dry/Burning/Itchy skin (62%)
The respondents were also asked if they had any
of 14 pre-existing health conditions including asthma, hay fever,
allergies and smoking. Thirty-four (34) respondents to the medical
questionnaire, representing 41% of the total, indicated that they
did not have any pre-existing health problems.
Office of Compliance - Re-Survey - Current
Conditions
We updated our employee survey during May 2002.
We re-surveyed by telephone all legislative branch employees who
originally contacted us to report symptoms.
One hundred sixty-eight (168) respondents were
reached by telephone in the re-survey. The results may be summarized
as follows:
- 55% of the 168 respondents reported
that they were still experiencing symptoms.
- 22% of these respondents have had their
duties changed with respect to handling mail.
- 78% of these respondents have not had
their duties changed with respect to mail.
- 38% of the respondents still experiencing
symptoms said the symptoms were unchanged.
- 61% of these respondents said the symptoms
were better.
- 1% of these respondents said the symptoms
were worse.
- 45% of the 168 respondents reported
that they no longer were experiencing symptoms.
- 20% of these respondents have had their
duties changed with respect to handling mail.
- 80% of these respondents have not had
their duties changed with respect to mail.
In connection with all the employee surveys we
conducted, we emphasize that the results do not represent a scientifically
valid sampling of Legislative Branch employees, but only of those
who elected to respond. Further, because of widespread publicity
regarding anthrax exposure and mail handling symptoms, it is possible
that many of the respondents were particularly sensitive to the
problem of handling mail at the time they completed the initial
Contact Information Sheet, during the call-back survey, in completing
the medical questionnaire, and in our re-survey in May 2002.
In summary, our several surveys of the effects
of handling irradiated mail disclosed that a substantial number
of Legislative Branch employees handling the mail initially displayed
significant adverse health symptoms. The number of employees affected
has declined in recent weeks, as has the seriousness of the symptoms.
Nonetheless, adverse employee health effects remain substantial.
Sampling and Testing of Legislative Mail
During February and March 2002, we conducted
our own sampling of the chemical by- products of irradiated mail,
using the most modern equipment available. With the assistance of
an industrial hygienist from OSHA's Health Response Team, we first
collected air samples from the polyethylene bags that had been irradiated
at a plant in Bridgeport, New Jersey, and at the Brentwood Post
Office in Washington, D.C. Through evaluation of the air samples,
we sought information about possible inhalation exposure. The results
from the samples indicated the presence of low levels of several
irritant chemicals, apparently produced from the paper during the
irradiation process. In order to determine whether these chemical
by-products were the cause of the employee complaints, we obtained
additional air samples from the House and Senate mail rooms. We
targeted the mail rooms because they are the sites where the highest
exposure concentration of any residual chemicals left in the mail
would be likely to reside. Again, our test results indicated the
presence of low levels of irritant chemical by-products caused by
irradiation of the mail.
In addition, several Congressional offices, including
Senator Grassley's office, offered us samples of the paper mail
they received so they could be chemically analyzed. We sought information
about possible dermal exposure through sampling of the paper. Once
again, the test results confirmed the presence of irritant chemical
by-products at low levels. Sixty (60) blank "test" letters
were then mailed to various participating Congressional offices,
and 10 were sent directly to the OSHA laboratory to serve as "controls."
After the 60 letters were irradiated and received (but not opened)
at the various Congressional offices, those too were sent to the
OSHA laboratory for evaluation. The methodology used by OSHA was
chromatography and mass spectrometry. The results of this testing,
like the previous testing, also indicated low concentrations of
several chemicals produced as by-products of the irradiation process.
In sum, our testing has indicated the presence
of certain irritant chemicals produced by the mail irradiation process,
but we have not yet been able to quantify the amounts of such chemicals
present in the mail upon its receipt in Congressional offices. Such
quantification may require more sophisticated testing, because of
the possibility that the by-products of irradiation dissipate over
time. Given the number of Congressional employees that we found
are still experiencing significant symptoms during our recent re-survey,
as detailed above, we believe that additional testing is necessary
to determine whether or not irritant chemicals, or other factors,
are the likely cause of the reported employee symptoms.
Executive Branch Agencies
With the exception of a limited study of possible
air contaminants done for the Office of Personnel Management ("OPM")
by NIOSH, on January 22 and 23, 2002, we are not aware of any studies
done to assess the possible effects of irradiated mail at Executive
Branch agencies. During April and May 2002, at our request OSHA
conducted an informal survey of employee complaints regarding the
handling of irradiated mail at certain Executive Branch agencies.
Some complaints of headaches, burning eyes, skin irritation and
nausea were found at the 10 Executive Branch agencies surveyed,
ranging in number from no complaints, but some inquiries, at the
Commerce Department, to a total of twenty complaints at the State
Department. We emphasize that OSHA conducted only an informal survey
at our request, and not a scientific analysis of Executive Branch
symptoms. There are many possible reasons for the differing results
in different Executive Branch agencies, such as different processes
for handling mail and different quantities of mail. Despite these
information limitations, we provide the responses OSHA obtained
as background information to our analysis of the Legislative Branch.
The results are summarized in Attachment C to this report.
IV. Decontamination of Hart Senate Office
Building
In addition to Senator Grassley's request for
an investigation of health complaints of Senate employees relating
to irradiated mail, his request also referred to "between 50
and 60 employees in the Hart Building (who) have complained of dry
eyes, dry throat and headaches." Based on the Senator's report
of these general complaints by employees located in the Hart Building,
as distinguished from complaints specifically relating to opening
and handling mail, we sought to determine whether the more general
complaints of symptoms may have been related to the decontamination
process utilized in the Hart Building.
In response to Senator Grassley's request, we
conducted air sampling in the Hart Building on February 15, 2002.
The inspection was conducted by an industrial hygienist on the staff
of the General Counsel, utilizing equipment and methodology approved
by the Occupational Safety and Health Administration. We sampled
for chemicals which would most likely be associated with the decontamination
process, specifically, ozone, chlorine dioxide, carbon monoxide,
and carbon dioxide. Our sampling did not reveal any levels of the
sample chemicals that would represent a significant threat to the
health and safety of Senate employees. It is noteworthy that a number
of other events occurred at or around the time that the Hart Building
was reopened in January 2002, such as painting, and installation
of new carpet, in many areas. These events may account for some
of the symptoms reported by employees. In addition, several weeks
had elapsed between the re-opening of the Hart building and our
air sampling on February 15.
We received very few complaints directly relating
to the Hart Building decontamination process (as distinguished from
the 215 complaints directly relating to the handling of irradiated
mail). Since those few initial complaints came in, we have not received
any additional complaints regarding decontamination of the Hart
Building. Accordingly, the General Counsel intends to close this
aspect of the investigation, in the absence of any further information
from employers or employees which might indicate possible health
risks associated with the decontamination process.
V. Observations Regarding our Investigation
Upon the written request by any covered employee
or employing office of the Legislative Branch, the General Counsel
of the Office of Compliance is required by the Congressional Accountability
Act to investigate the health and safety of workplace conditions.
We received such requests from a United States Senator and two House
employees. Nonetheless, our investigation did not proceed as smoothly
as we would have liked.
We sought an unredacted copy of the NIOSH study
of irradiated mail from the Sergeant at Arms of the Senate - - who
chairs the Legislative Mail Task Force - - on March 22, 2002. We
agreed to maintain the confidentiality of the report by whatever
means were deemed necessary by that Office. We never received an
unredacted copy. We also asked to accompany the NIOSH team as they
conducted their irradiated mail investigation commencing in February
2002. We were not permitted to participate in this investigation.
We did, however, speak with NIOSH staff on May 15, after the investigation
was completed. However, our non-participation in the investigation
and the failure to obtain an unredacted copy of the NIOSH report,
made it more difficult for us to determine the chemical by-products
of irradiation that NIOSH studied, other factors considered by NIOSH
and what NIOSH found.
We asked the Office of the Attending Physician
to share with us the results of a re-survey that office conducted
of employees who had experienced adverse symptoms in connection
with handling irradiated mail, subject to deletion of patient information.
We wanted to compare our re-survey data with that of the Attending
Physician. The Office of the Attending Physician has not shared
that information with us (even with employee identities redacted)
as of this date.
We also requested (in writing) that the National
Oceanic and Atmospheric Administration, the Armed Forces Radiobiology
Research Institute (AFRRI), the Defense Advanced Research Projects
Agency and the United States Postal Service (USPS) meet with us
in connection with our investigation. We requested assistance from
these agencies because we understood that AFRRI had conducted research
in support of the NIOSH study directed by the Legislative Mail Task
Force, as had the Defense Advanced Research Projects Administration.
We also understood that the National Oceanic and Atmospheric Administration
had conducted research on mail problems at that agency. We never
received a response to our requests for assistance from these agencies.
We did engage in a conference call with an official of the USPS,
which was quite helpful. We were advised that USPS believed there
had been a problem with some "overdoses" of irradiation
at the commencement of the mail irradiation process and that it
had been corrected. However, the USPS official's promise to arrange
for a meeting with the other agencies referred to above, as well
as with the White House Office of Science and Technology, was not
fulfilled although we telephoned several times to request such a
meeting.
The Chief Administrative Officer of the U.S.
House of Representatives furnished, at our request, a copy of a
report of an analysis by AFRRI of discoloration of gloves utilized
by mail handlers. AFRRI attempted to extract mail related chemicals
which might be affecting employees in the mail handling process.
The AFRRI study found that there were no detectable
chemical by-products present in the gloves. However, the AFRRI report
stated:
The absence of detected analytes does not indicate
that mail-related chemicals were absent, but that any such analytes
were not detectable using these methods. Additional work is underway
to elucidate the mechanisms that could alter large polymeric compounds
present in paper, such as cellulose... This work is ongoing and
the remaining gloves could be useful once the mechanism of chemical
alteration of cellulose (if any) is identified and analytes are
known.
With the sampling methods used, no harmful
contaminants were detected on the gloves.
While we believe we have reached appropriate
conclusions in this report, our investigation might have been more
effective and certainly would have been completed more promptly
and efficiently, if we had not encountered a lack of cooperation
by some agencies and officials.
VI. Potential Causes of Employee Symptoms.
Our investigation and testing of irradiated mail
handling has not thus far established a single definitive cause,
or causes, of the broad range of symptoms reported by Legislative
Branch employees. We believe these symptoms are not insignificant,
both in terms of the number of complaints and in the effect on employee
health and work performance. The NIOSH report found that heightened
awareness and resultant stress from the recent terrorist attacks
may have contributed to employee symptoms. We believe this factor
may have been a contributing cause, but our research persuades us
that chemical irritants and other factors may also be contributing
causes of the symptoms experienced by Legislative Branch employees.
Some of our tests have indicated the presence,
at low levels, of several chemical by- products of irradiated mail
that are definite irritants. These chemical by-products probably
emanate from the cellulose contents of the paper mail which is broken
down in the intense irradiation process. We have not yet been able
to quantify the amounts of these by-products in the mail, possibly
because of the unavoidable time lapse in obtaining our air and bulk
mail samples and their receipt by the OSHA Salt Lake Technical Center
for testing. While we do not believe these chemical irritants are
life-threatening we believe further study is essential to determine
the effects of extended exposure to irradiated mail, particularly
in restricted work areas.
Based on our investigation thus far, and the
statutory mandate of the Congressional Accountability Act we recommend
at least three additional actions to assure the protection of Legislative
Branch employees who handle irradiated mail.
- Continued Monitoring.
We believe it is essential that health professionals, either in
the Office of the Attending Physician, or independent medical
professionals, monitor on a regular basis those employees who
report symptoms which they believe are based on handling of irradiated
mail. The monitoring should continue until there is evidence that
the symptoms reported have declined significantly. The results
of this continued monitoring should be reported to the Office
of the Attending Physician and simultaneously (using our Contact
Information Sheets which are available on our website www.compliance.gov)
to the Office of Compliance.
- Additional Studies.
We recommend certain additional studies designed to investigate
the longer-term exposures to irradiated mail of Legislative Branch
employees. These additional studies would focus primarily on the
degree of exposure to irritant chemical by-products of irradiated
mail which employees could face over typical work periods, in
typical office settings on Capitol Hill. They would also deal
with varying levels of mail and different mail handling procedures.
Such studies could probably be completed within a year, and could
be performed by outside testing organizations under contract to
the Office of Compliance. Such studies are beyond current Office
of Compliance resources and would require approval of additional
funding by Congress. (See Section VII below).
- Basic Interim Precautions.
We also recommend that certain basic interim precautions be taken
by employers and employees who handle mail on a regular basis.
These interim steps would be designed to minimize any possible
health risk which might be found in the future from the long term
handling of irradiated mail. (See Section VIII below).
Further discussion of our recommended actions
is contained in the following two sections of this report.
VII. Additional Studies Recommended.
We believe, as already indicated, that additional
studies are necessary to investigate the safety of handling irradiated
mail. Both Dr. Laura Welch and Dr. Clifford Mitchell, who are experts
in occupational medicine, concur in this evaluation.
The studies we recommend should include:
- Consideration of a medical study of employees
who display continued symptoms from handling mail, to attempt
to better characterize potential causes.
- A workplace exposure assessment to determine
if chemical by-products present in the mail, or other factors,
could represent a serious health hazard to employees under specific
exposure conditions.
- Development of additional data on the physical
and chemical properties involved in irradiation of mail and their
possible effect on Legislative Branch employees.
VIII. Interim Steps.
While the additional studies we recommend are
in process, we suggest that Legislative Branch employees handling
irradiated mail take some basic precautions to limit exposure. Employing
agencies should, we believe, implement the following:
- Employees who manifest symptoms which appear
to be related to mail handling should obtain a medical evaluation
and should determine whether to wear gloves in consultation with
a physician. If the determination is made to wear gloves by employees,
the gloves should preferably be non-latex. Legislative Branch
employers should make appropriate gloves available.
- The mail should be thoroughly aired-out, probably
by the U.S. Postal Service, prior to transmission to legislative
offices. This airing-out period should not be truncated by understandable
pressure to deliver constituents' mail promptly.
- Employees should wash hands thoroughly after
they complete mail handling duties, preferably using moisturizing
lotion after washing.
- Employees should handle mail in well-ventilated
areas.
- Where employees display continued symptoms
from exposure to irradiated mail, consideration should be given
to reducing their exposure.
- If employees experience symptoms such as those
we found in the course of our investigation, they should report
these symptoms to the health offices of their Legislative Branch
organizations, and separately forward this information to the
Office of Compliance. (using the Office of Compliance Contact
Information Sheet, found on the OOC website at www.compliance.gov)
Conclusion
Handling irradiated mail for substantial periods
of time may be the cause of adverse health symptoms in a significant
number of Legislative Branch employees. These symptoms have continued
to be evident in a recent re-survey by the Office of Compliance,
although the number of affected employees and the severity of symptoms
has declined. We do not currently have enough information to reach
any final conclusion on whether there is any serious
health risk from extended periods
of mail handling under existing working conditions. We do recommend
that additional studies such as those discussed in Section VII be
undertaken in order to attempt to reach a firm conclusion on any
health risks to which employees might be exposed. We believe these
studies are essential to safeguard the right of covered employees
to work in a place free from recognized hazards that are causing
or are likely to cause serious physical harm.
Pending the results of further irradiated mail
studies, we recommend that employers and employees take some basic
precautions, such as wearing protective gloves if they display symptoms
when handling irradiated mail and, in general, reducing exposure
when symptoms are present by limiting the amount of time individual
employees expend in mail handling.
The General Counsel and the Office of Compliance
will report further on this investigation as we develop additional
information.
ATTACHMENTS:
- Senator Grassley's Request for Investigation
- February 11, 2002
- General Counsel's Memorandum & Contact
Information Sheet - February 21, 2002
- Survey of Selected Executive Branch Agencies
Conducted by OSHA - April/May 2002.
Survey of Selected Executive
Branch Agencies
Conducted by OSHA - April-May 2002
Department |
Mail Complaints |
Agriculture |
Two complaints of acute skin irritation (per health unit).
|
Commerce |
A few inquiries. |
HHS |
Two inquiries, no complaints.
Timing: At beginning of irradiation
effort
Symptoms: Burning eyes, some
concern regarding residue on surfaces they touched. |
HUD |
A few inquiries, no complaints. |
Interior |
More than twelve complaints.
Timing: Since beginning of irradiated
mail deliveries until now
Symptoms: Puffy eyes, headaches,
nausea, itchy skin (no rashes seen) |
Justice |
Four complaints.
Timing: All in past month.
Symptoms: Puffy eyes, itchy
skin on hands. |
Labor |
No complaints filed with the Baltimore-DC Area Office, Norfolk
Area Office, or Philadelphia Office (Region III). |
State |
More than twenty complaints.
Timing: All at beginning of
process (Note: just received large shipment of mail that was
high load and thus was given higher dose, yet no complaints).
Symptoms: Raspy throats, itchy
eyes, headaches. |
Treasury |
No complaints, just inquiries regarding crunchy papers and
melted plastic. |
VA |
Six contacts including three serious inquiries. Three complaints
of ill health.
Timing: When irradiated mail
first distributed. Last six weeks have been quiet.
Symptoms: Lightheadedness, dizziness,
nausea, itchy skin. |
|
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