MassCOSH Health and Safety Review for MBTA Janitors 8-12-14
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Transcript of MassCOSH Health and Safety Review for MBTA Janitors 8-12-14
August 2014
1532 B Dorchester Ave. 1Dorchester, MA 02124 617‐825‐7233 617‐929‐0434 www.masscosh.org
Review of Health and Safety Conditions for Contracted MBTA Janitors
MassCOSH was asked by SEIU32BJ District 615 to assist them in a review of current health and safety standards at the MBTA and to assess the impact that staffing cuts, scheduled to go into effect September 1, 2014, might have on the remaining workforce as well as the general public. The following describes our review, defines our concerns and shares our opinion of the detrimental effect staffing cuts will have on maintaining adequate health and safety protocols at the T.
MassCOSH and the union have jointly conducted over 20 in‐depth interviews to date with a representative sampling from each of the affected subway lines. Additionally, MassCOSH has reviewed bid documents of the sub‐contractors (SJ Services and ABM), their Productivity Enhancement Plans, pertinent standards of the Occupational Safety and Health Administration (OSHA), and researched available information about the new equipment and green cleaning program.
Our review raises the following concerns:
Workers clean messes containing body fluids, including blood, feces and vomit without the proper equipment and training necessary for protection from infectious disease, including potentially fatal infections such as HIV and hepatitis B.
Workers reported regularly disposing discarded needles without training on safe disposal procedures as required by Federal law (OSHA’s Blood Borne Pathogen Standard) including offering workers hepatitis B vaccinations.
The interviews documented instances of workers without enough supplies to clean. This is a concern because cleaning bathrooms without the proper cleaning fluids or enough supplies can result in ineffective disinfection of surfaces.
Workers are already experiencing speedup and increased workload at stations that experienced a nearly 9% cut in staff levels in the past five years.1 They state that they will
1 4% staffing reductions in the four years prior to when the current contract was awarded. (MBTA IFB 46‐13, Stations and Facilities Cleaning Services, Scope of Work, pp. 16‐17). In addition, year 1 of the current contract included up to 5% cuts through attrition.
“I find discarded needles 3‐5 times a week. I put them in a plastic bottle and throw it in the trash. I did not receive training on needles.”
Janitor on the Green line,
covering 13 stations
2
not be able to keep up with the necessary cleaning after even more cuts. This presents safety and health concerns because when workers rush to finish tasks, it can increase stress and the potential for work‐related injuries.
We are greatly concerned about the increased health and safety risk to the general public.
Based on the review we’ve been able to complete, the
following in our opinion should be taken into
consideration before implementation of any changes
to current staffing, equipment, or other protocols affecting health and safety.
Hazardous Exposures for Cleaning Workers at the MBTA
Chemicals
Cleaning workers are exposed to cleaning and disinfecting chemicals in their work that can contain hazardous ingredients which can cause asthma, burns and skin problems. While chemicals can be hazardous if not diluted or used properly, they provide protection against exposure to ‐ blood borne pathogens – potentially infectious blood & body fluids and other bacteria and viruses often found in the bathrooms and surfaces which the public touch at the T stations. Improper use of chemicals and disinfectants to kill potential infectious material poses a health threat to the workers as well as the traveling public who use the T.
Although we did not receive a list of the cleaning products used by the cleaners, workers interviewed reported that they frequently use bleach as one of their “cleaning” products. One worker reported that a former supervisor told him to use the bleach “full strength”. The worker’s common sense told him that this would not be safe. Seven of the twenty workers interviewed said they did not receive training about the chemicals they use and over half stated that they often don’t have enough cleaning supplies (cleaning fluid, rags, paper towels, protective gloves) to do their work well. Of the twelve that stated that they did receive training on chemicals in the last year ‐ one said he was told to look at a binder with safety information in it. The correct dilution, application and dwell time for disinfectants and skilled use of cleaning procedures and equipment are crucially connected with the chemicals used in order to properly clean for the health and safety of the workers and the public who use the facilities.
One worker told us: “They don’t give us liquid for mopping. I mop with water only. For the past
2 weeks there hasn’t been hand soap for the bathrooms.”
In describing how the bathrooms were cleaned, it seemed that there may be an over‐reliance on bleach as a “cleaner” because of the concern about odors and the prevalence of body fluids found in the bathrooms and other places in the stations where people urinate or defecate. Bleach is a chlorine‐based corrosive substance used as a disinfectant in janitorial work. Even bleach that has been diluted can cause skin burns, irritation to the eyes, nose and throat, cause
“Traveling cleaning teams – that can’t
work. We’re not airplanes. There’s stuff
happening all the time. No one wants to
know about this gross stuff but it happens.
If no one’s there (to deal with these
messes), we’ll have to go back to the
station (after first waiting for a train!).”
Janitor on the Blue line,
26 yrs at the MBTA
3
asthma flare ups and respiratory irritation. Bleach can initiate asthma in adults who have never had asthma. Since this chemical is a registered pesticide, powerful enough to kill even the worst bacteria, it makes sense that it poses a danger to those who use it, and to anyone exposed to it. Bleach is particularly harmful to young children who may be using bathrooms in the T, because their immune systems are less developed to fight off the harsh chemicals. Above all, it is not a “cleaner”‐ rather a disinfectant that that is only effective in killing germs and infectious material if it is used after a surface is cleaned of all surface dirt and contamination.
Exposure to Infectious Material
Cleaning workers at the MBTA Stations are regularly exposed to potential infectious material such as body fluids (blood, vomit, and urine), bacteria and viruses and discarded needles found in the course of performing their cleaning duties. Left unprotected, and without proper receptacles to dispose of them, these needles pose a serious puncture wound hazard and potential exposure to infectious diseases. A janitor assigned to a busy T‐station told us that he typically finds 2‐3 discarded needles a day during his cleaning duties. Another cleaner stated that his co‐worker had received a needle stick injury when the needle pierced the plastic trash bag that he was changing. Nine of the twenty workers interviewed told us they find discarded needles on a daily basis. Among the twelve cleaner’s employees that stated they had received training on chemicals – only three said they also received training on safe handling and disposal of needles. When asked to describe the procedure they use to safely handle the discarded needles, responses ranged from:
“I put it in an empty plastic bottle and call a supervisor.”
“I put the needle in a plastic bottle and put it in the trash.”
“I throw it in the trash” The Occupational Safety and Health Act’s (OSHA) Blood Borne Pathogen Standard (Title 29 of the Code of Federal Regulations at 29 CFR 1910.10302) requires the employer to create an Exposure Control Plan. “Employers must update the plan annually to reflect changes in tasks, procedures, and positions that affect occupational exposure, and also technological changes that eliminate or reduce occupational exposure. Employers must also document that they have solicited input from frontline workers in identifying, evaluating, and selecting effective engineering and work practice controls.” MassCOSH was not able to request this plan from the cleaning sub‐contractors in time for this report. However, the worker interviews reveal a “catch as catch can” picture of uneven cleaning procedures, lack of training and cleaning supplies/equipment and for the potentially serious exposure to infectious disease.
2 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10051&p_table=STANDARDS
4
Heavy Lifting and Repetitive Tasks
Cleaning workers regularly perform heavy lifting such as emptying full trash barrels and shoveling snow and ice in the winter, and repetitive tasks such as mopping and washing/ wiping windows, metal and other surfaces. This work already has the potential for causing musculoskeletal injuries to the shoulders and back, as well as costly worker compensation claims. With fewer cleaning hours, it is likely that trash cans will be emptied less frequently – potentially resulting in workers carrying heavier bags ‐ increasing the risk of musculoskeletal injuries.
An average worker injury can add up to more than $50,000 for a back injury and more than $60,000 for a slip and fall injury. These costs do not include additional, indirect costs associated with injuries and illnesses such as lost productivity, re‐training, hiring new employees, and administrative time. Cost data cited is from the Workers’ Compensation Insurance Rating Bureau of California in 2008.3
Increased Workload
Workers interviewed were reporting that they don’t have enough time to do the work they’re currently assigned – so they are rushing to get things done which increases the risk of injury. Several workers told us that they were already working with fewer staff initiated in the last contract. Increased workload causes fatigue and stress, resulting in negative health effects. For example, job strain is related to cardiovascular disease and coronary heart disease. Overwork can not only affect heart disease, but also mental health can increase the risks of obesity.i With the projected cuts of 29% of the workforce and 25% reduction of total cleaning hours worked – it is not hard to predict that cleaning tasks will be completed less frequently and require more intense work, with a greater risk of worker injury and the public encountering bathrooms and other areas that have not been inspected or cleaned. In addition the reduced cleaning hours written into contract bids from SJS and ABM do not account for the increased ridership with the new late night T service (which has accounted for 400,000 additional riders since January)4 as well as the upcoming addition of Boston middle school students5 and the extra cleaning demands associated with the ridership increase.
3 https://wcirbonline.org/wcirb/resources/data_reports/pdf/2008_loss_and_expenses.pdf 4 Martine Powers, “MBTA says late‐night ridership is steady,” Boston Globe, 8/6/2014. http://www.bostonglobe.com/metro/2014/08/05/mbta‐experiment‐late‐night‐service‐passes‐mark/RSbD3AP9CEXODuWM8MRr4K/story.html 5 Andrew Ryan, “Middle‐schoolers to ride MBTA under new city budget, Boston Globe, 6/25/2014.
5
Health and Safety Impacts on the Traveling Public
The traveling public – infants, children, adults, those with disabilities and other workers using the T – as well as tourists from all over the world are exposed to some of the same hazards as the cleaning workers are and they also transmit some of those hazards. The public touch many surfaces in their travels on the MBTA such as stair and escalator railings, ticket machines, elevators doors and buttons and bathrooms. Each of these “touch points” can create a chain of transmission for infection, bacteria and viruses either from a contaminated surface to a person’s hands or from their own hands contaminating a surface. The Centers for Disease Control states that hand washing is one of the best ways to prevent the spread of infection,6 however it is not easy to manage the hygiene behaviors of the traveling public. One of the key public health roles that MBTA cleaning workers provide is to regularly inspect bathrooms during all rider hours, to ensure adequate hand washing supplies and to clean up potentially infectious contamination. Any decrease in the frequency of inspection and cleaning increases the likelihood that contamination may remain and may spread to others. The proposed staffing cuts make it hard to believe that these public health practices and the time needed to meet infection control standards were taken into account in the contracts.
Green Cleaning and Productivity Projections
SJS and ABM cleaning contractors base much of their rationale for reducing staffing on productivity projections. These are identified primarily as:
lost productivity during the peak travel times‐totaling approximately 9 hours per day,7
and productivity increase due to the introduction of a “green cleaning” program and introduction of new equipment.
Lost Productivity during Peak Travel Times
The rational for reducing staffing during peak travel times is that it is difficult to do heavy
cleaning while the station is occupied. Although cleaners who were interviewed did
acknowledge some challenges to heavy cleaning during the day, they also stated that they were
busy with other tasks that had to be done as well.
“I am able to pick up trash under the benches or in the corners. If I see a spill, I will wait for
people to get on the trains. “
“No! I am able to clean as usual even when with passengers at the station.”
Tasks on the workers’ “Quality Control Inspection Form” identify approximately fifteen tasks
performed to meet the cleaning standards for the bus shelters, entrance and lobbies, stairways,
6 http://www.cdc.gov/features/handwashing/ 7 Morning Rush: 5:30am‐9:30am, Lunch: 12‐1:30pm, After School: 3‐4, Evening: 4‐6:30pm, SJS Phase 2 Response IFB 46‐13 Station and Facility Cleaning Services, Work Area 3, 4/15/13, p 65.
6
platforms, pits, booths, escalators, elevators, restrooms and offices. The tasks include:
sweeping, mopping, washing and replacing bathroom supplies, cleaning glass and all metal
surfaces (doors, railings machines), graffiti control, removing gum, changing trash and recycling,
picking up litter inside and out of station, changing light bulbs and dusting. As stated earlier in
this report – cleaners interviewed stated that they are already having difficulty getting through
all the cleaning tasks. Although the reorganization of cleaning tasks with the new equipment
may change the order in which they are performed and the time of day – the majority of these
tasks seem necessary on an hour by hour basis to monitor cleanliness, manage spills and the
more hazardous body fluid exposures and to keep bathrooms well stocked. MassCOSH has not
seen the contractors’ detailed staffing plan for Years 2‐5 so there is no way to estimate what
percentage of the stations may have no cleaning staff for hours at a time.
Although “traveling cleaning teams” are being proposed as a solution to lost productivity – that
will still leave gaps in cleaning capacity during peak travel times – a concern given the frequency
of spills and other accidents. It is unclear how quickly these teams will be able to monitor
cleaning needs and respond to them considering travel time in and around peak hours and the
reality that there will be fewer workers overall cleaning these stations.
In a cleanliness survey the MBTA conducted in May 2014 among 2,335 of the traveling public, almost half (46%) of those that responded to a question about bathroom cleanliness said they were “unclean, very unclean, and somewhat unclean” on that day. Fifty-four percent replied that the bathrooms that day were “neutral” or said the bathroom was “somewhat clean, clean, very clean.”8
Green Cleaning Program Used to Support Increased Productivity Projections
SJS and ABM cleaning contractors market their “Green Cleaning Program” aggressively as an
efficiency and productivity program in the contract bid and the Productivity Enhancement Plan
(PEP). Although the description of the new products and equipment provided in the PEP is
consistent with some aspects of a good Green Cleaning Program, the associated productivity
claims are marketed through the vendors of the new equipment – not a Green Certified
program such as Green Seal, a well‐respected 3rd party certified program or the newer
International Sanitary Supply Association (ISSA) Cleaning Industry Management Standard.9 We
consider the productivity claims “couched” in a green cleaning program to be misleading and
inaccurate.
SJS bases their productivity claims on one of the components of the Rubbermaid Inc. system
designed for the London UK Transit system. Although they state that this system has proven
8 MBTA Station Cleanliness Survey, conducted May 22 and 29, 2014. Obtained July 29, 2014 via Open Records
request. www.mbta.com/cleaningsurvey. 9 http://www.issa.com/?id=cleaning_industry_management_standard_cims
7
highly successful, we have heard that it has caused labor unrest in London in response to the
similar aggressive cuts of 30% of the cleaning workforce.
In researching the Rubbermaid and
KaiVak equipment it is clear that there are
aspects to the equipment that could
enhance worker health and safety and
public health. However, it is not clear how
a drastic reduction in the workforce who
will use this equipment is any indication
of how a green cleaning program should
be run according to the descriptions of
the two green program certifiers referred
to in the contract: Green Seal, and ISSA
Cleaning Industry Management Standard.
It is also not clear that even with state of the art equipment, these vendor claims are accurate
in regards to the staff needed to use them successfully.
Day‐time cleaners will be using slightly updated equipment with the introduction of micro fiber
cloths and spray bottles of cleaners. Taking into account the current problems reported in our
interviews, regarding inconsistent availability of cleaning supplies, protective equipment and
the time needed to clean well ‐ the introduction of new technology and staffing plan may be
putting the “cart before the horse.” And the public health hazards for those traveling on the T
may become even more troublesome.
Although the vendors state that the
worker productivity claim is
documented through their testing and
performance measures, the testing
done in Boston appears to have been
limited and was not shared with the
union. MassCOSH has not seen the data
behind vendors’ testing efforts nor was
it submitted as part of the bid documents so we cannot evaluate their thoroughness. Any
program that introduces such an ambitious investment in new equipment and products should
be rolled out in a phased program with participation from the workers and their union.
It is dubious that an overhaul in cleaning staffing based on decreased cleaning during the day and new equipment can yield high standards given that workers currently face a range of problems related to supplies and equipment and encounter numerous unplanned messes throughout the day that need adequate staffing to address in a timely and safe manner.
The term “green cleaning” highlights the need to clean up the cleaning processes and products themselves, because many commonly used interventions contain, add, or leave environmental pollutants or may cause harm in other ways. Green cleaning benefits the environment and helps protect people, especially vulnerable populations such as the elderly, the infirm, children, and the chemically-sensitive. Their long- or short-term exposure to toxic chemicals or harmful particles, gases, or vapors can have serious consequences such as asthma, allergies, depression, hormonal changes, or even cancers.
–www.GreenSeal.org, Green Building Operations and Maintenance Manual
“We don’t have enough gloves. They never provide enough
trash bags. I had to buy a little knife to be able to scrape gum
off the platform because the company wouldn’t provide me
with a tool to do it. They give us one liquid to clean
everything ‐ windows, walls, toilets. It doesn’t work. We’re
given rags but are told to wash them and reuse them which is
time consuming.”
Janitor on the Blue line, 18 yrs at the MBTA
8
The following table illustrates some of the risks and areas of concern in order to assess the range of potential impacts on public health anticipated with
the staffing cuts.
Exposures Conditions that can affect outcomes Effects Cleaning Workers Traveling Public
Chemicals
Cleaning products Disinfectant:
o Bleach
Availability of room cleaning supplies (paper towels, buckets, etc.)
Availability of personal protective equipment
Clear directions and standard operating procedures about cleaning and disinfecting steps (eg dilution and dwell time)
Chemical information including material safety data sheets, posted in area
Adequate time and personnel to use the products as directed
Training about chemical safety for cleaning employees
Risk of new cases of asthma and worsening of existing asthma
Risk of bronchitis or COPD exacerbation
Skin and eye irritation Splash injuries
Irritation—leading to asthma symptoms, or eye irritation, or dermatitis (children are more vulnerable)
Infectious Materials: Body fluids
Hypodermic needles
Bacteria, viruses
Timely checking for contamination and response
Timely checking for adequate hand washing supplies
Directions and standard operating procedures for removing, cleaning and disinfecting contamination
Safe disposal boxes for needles Training about safe handling of needles and other sharps
Training about infectious materials and methods to safely clean and disinfect
Hepatitis B vaccinations offered on work time
Contact and potential exposure to blood or other body fluids and infectious bacteria and viruses (e.g. Hepatitis A)
Risk of needle stick injury; possible need for post exposure prophylactic drugs
Risk of infections from sharps such as HIV and hepatitis B
Question about completeness and compliance with “Exposure Control Plan” required by OSHA
Lack of bathroom supplies (such as soap and paper towels ) and proper cleaning and disinfection procedures contribute to spread of infectious disease
Less frequent and timely cleaning of potentially infectious material may increase spread of disease
Risk of needle stick injuries; possible need for post exposure prophylactic drugs o Discarded needles pose a health
threat to children who may pick one up and to adults who may come into contact with them or act as a “good Samaritan” and dispose of them improperly
9
Exposures Conditions that can affect outcomes Effects Cleaning Workers Traveling Public
Workload and Cleaning Tasks
Increased pace of work can lead to rushing through tasks and/or skipping tasks that can affect health and safety (i.e. Infectious material, overloaded trash barrels)
Increased workload increases repetitive tasks and may increase heavy lifting (trash)
Performance standards have not adequately assessed and tested the ability to do all cleaning tasks such as responding to spills (from soda to body fluids)
Worker’s fears and stress about job uncertainty due to layoffs and short staffing
Potential for disabling musculoskeletal work‐related injuries, lost work time and productivity
Increase exposure to: o infectious material o slippery surfaces o pests
Increased job stress may increase the risk of stress‐induced injury and illness, with possible cost shifting to health insurers and out of pocket costs to workers rather than to the
workers compensation system.10
Increased workload may lead to gaps in cleaning task completion that could lead to hazards described above.
Increase exposure to: o infectious material o slippery surfaces o pests
10 http://www.ncbi.nlm.nih.gov/pubmed/23662682
10
Summary
Based on our review of current health and safety conditions, we believe there is an urgent need
for the MBTA management to take immediate steps to reassess the scheduled staffing cuts –
particularly for those proposed by SJS. Considerations should include re‐visiting productivity
claims for the Y2‐5 Green Cleaning program resulting in the projected job cuts; assurance that
systems are in place to provide adequate supplies for the necessary cleaning and disinfecting
tasks; that worker training is consistent with the OSHA Hazard Communication Standard and
Blood Borne Pathogen Standard; and there is a commitment to a labor‐management program
that would include worker input, advance notice and testing of new green cleaning and
environmentally preferable products, work practices and introduction of new equipment that
affect workload, safety and health.
i 1. Belkic KL, Landsbergis PA, Schnall PL, Baker D. 2004. Is job strain a major source of cardiovascular
risk? Scan J Work, Environ Health 30(2):85‐128.
2. Kivimaki M, Virtanen M, Elovainio M, Kouvonen A, Väänänen A, VahteraJ. 2006. Work stress in the
etiology of coronary heart disease—a meta‐analysis. Scan J Work, Environ Health 32(6):431‐442.)
3. Overwork can not only affect heart disease, but also mental health (Godin I, Kittel F, Coppieters Y,
Siegrist K. 2005.
4. A prospective study of cumulative job stress in relation to mental health. BMC Public Health 5(67):1‐
10. http://www.biomedcentral.com/content/pdf/1471‐2458‐5‐67.pdf and can increase the risks of
obesity, http://escholarship.umassmed.edu/cts_retreat/2013/presentations/7/