HETA 2001-0316-2865

Independent Leather

 US Environmental Protection Agency Superfund Site

Gloversville, New York

Lisa J. Delaney, M.S.

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally

applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved.

Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally

applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved.

Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally

applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved.

applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved.

Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports
ii

PREFACE

The Hazard Evaluations and Technical Assistance Branch (HETAB) of the National Institute for

Occupational Safety and Health (NIOSH) conducts field investigations of possible health hazards in the

workplace. These investigations are conducted under the authority of Section 20(a)(6) of the Occupational

Safety and Health (OSHA) Act of 1970, 29 U.S.C. 669(a)(6) which authorizes the Secretary of Health and

Human Services, following a written request from any employer or authorized representative of employees,

to determine whether any substance normally found in the place of employment has potentially toxic effects

in such concentrations as used or found.

HETAB also provides, upon request, technical and consultative assistance to Federal, State, and local

agencies; labor; industry; and other groups or individuals to control occupational health hazards and to prevent

related trauma and disease. Mention of company names or products does not constitute endorsement by

NIOSH.

ACKNOWLEDGMENTS AND AVAILABILITY OF REPORT

This report was prepared by Lisa Delaney of HETAB, Division of Surveillance, Hazard Evaluations and Field

Studies (DSHEFS), Atlanta Field Office (AFO). Field assistance was provided by Angela Weber. Desktop

publishing was performed by Pat Lovell. Review and preparation for printing were performed by Penny

Arthur.

Copies of this report have been sent to employee and management representatives at the Independent

Leather EPA Superfund Site in Gloversville, New York, and the OSHA Regional Office. This report is not

copyrighted and may be freely reproduced. Single copies will be available for a period of three years from

the date of this report. To expedite your request, include a self-addressed mailing label along with your

written request to:

NIOSH Publications Office

4676 Columbia Parkway

Cincinnati, Ohio 45226

800-356-4674

After this time, copies may be purchased from the National Technical Information Service (NTIS) at

5825 Port Royal Road, Springfield, Virginia 22161. Information regarding the NTIS stock number may be

obtained from the NIOSH Publications Office at the Cincinnati address.

For the purpose of informing affected employees, copies of this report shall be

posted by the employer in a prominent place accessible to the employees for a

period of 30 calendar days.
iii

Highlights of the NIOSH Health Hazard Evaluation

Evaluation of Hazards at Independent Leather

Environmental Protection Agency Superfund Site (EPA)-

Gloversville, New York

In July 2001, NIOSH assisted the EPA at a Superfund Site of the former Independent Leather in Gloversville,

New York. NIOSH evaluated the potential for exposures to anthrax and other microorganisms during the

clean-up of animal hides, fleshings, and hair that were abandoned when the tannery closed in 1994. NIOSH

also provided recommendations on work practices and procedures for removing the biological waste. 

What NIOSH Did

# We toured the buildings to look at microbial

growth.

# We reviewed records of previous owners.

# We spoke to EPA and remediation workers about

the site.

# We researched the hazards of anthrax.

What NIOSH Found

# No guidelines or standards exist that address the

hazards associated with the remediation of

tanneries.

# The potential for exposure to anthrax is minimal,

and infection in humans due to breathing anthrax

spores is rare.

# Visible mold growth was present throughout the

buildings.

# Employees are adequately trained for chemical but

not biological hazards.

What the EPA Can Do

# Train workers on biological hazards, and proper

mold clean-up methods.

# Continue current PPE use and remediation

activities, including the use of an isolation barrier.

# Mist area with water before remediation work to

reduce dust and mold in the air.

# Discard porous material contaminated with mold in

a sealed bag.

# Clean non-porous materials with a detergent

solution or bleach for reuse.

What Remediation Employees

Can Do

# Follow all safety rules and procedures.

# Wear the recommended PPE (full-face re spirator),

suit, gloves, and boot covers while working.

# Contact a medical professional if you suspect you

are infected with anthrax.

What To Do For More Information:

We encourage you to read the full report. If you

would like a copy, either ask your health and safety

representative to make you a copy or call

1-513/841-4252 and ask for

 HETA Report # 2001-0316-2865
iv

Health Hazard Evaluation Report 2001-0316-2865

Independent Leather 

US Environmental Protection Agency Superfund Site

Gloversville, New York

September 2001

Lisa J. Delaney, M.S.

SUMMARY

On May 21, 2001, the National Institute for Occupational Safety and Health (NIOSH) received a request for

technical assistance (TA) from the United States (US) Environmental Protection Agency (EPA) concerning

a Superfund Site at a former tannery, Independent Leather, in Gloversville, New York. The EPA asked

NIOSH to determine the health hazards to remediation workers from exposure to biological contaminants at

the site. Sources of biological contaminants at this site included animal hides, fleshings, and hair, which were

abandoned when Independent Leather declared bankruptcy in 1994. EPA employees were concerned about

the potential for exposure to anthrax and other microorganisms during planned remediation activities. NIOSH

was specifically asked to evaluate potential employee exposures during remediation and to recommend proper

remediation guidelines and personal protective equipment (PPE). No health effects were reported. 

NIOSH investigators conducted a site visit on June 26-27, 2001. The purpose of the site visit was to review

the scope of the project, evaluate work practices and PPE, and discuss strategies to minimize exposures to

biological contaminants. The site visit consisted of an opening conference, a walkthrough of the EPA

hazardous waste site, and informal interviews with the EPA site coordinator and remediation contractor

regarding their work activities and the superfund site. 

Based on our review of this site and proposed scope of work, the potential for zoonotic disease from

remediation activities at this tannery is minimal. Most zoonotic diseases can only be spread while the animal

is still alive and would not survive outside a living host for extended periods. While Bacillus anthracis (B.

anthracis) can sporulate and survive for many decades, the potential exposure to remediation workers is

minimal due to the characteristics of the bacteria (low secondary aerosolization potential and high infectious

dose concentration). The likelihood of environmental transmission of anthrax, while theoretically possible, is

considered to be remote. Visible microbial contamination, consistent with mold growth that would occur in

unmaintained facilities, was present throughout the site. Remediation of the site will result in the disruption

of these microbiological reservoirs. Precautions to prevent dissemination and reduce the potential for

exposure to these bioaerosols is warranted.

The remediation protocols established by the EPA and the contractor were found to be prudent, and the

precautions and PPE requirements are likely sufficient in protecting workers during remediation activities.

Additional suggestions to further ensure the potential exposures to biological contaminants are minimized

include training workers on the hazards of biological contaminants and appropriate work practices.
v

The potential for remediation worker exposure to anthrax spores at the former tannery appears

to be minimal. However, conditions within the abandoned buildings were conducive for promoting

mold growth. Prudent precautions, including PPE and work practices, should be taken to reduce

potential bioaerosol exposures. Recommendations are provided on PPE, training, and work

practices.

Keywords: 4953 (Refuse Systems), superfund site, remediation, biological contaminants, anthrax, zoonotic

disease, tannery
TABLE OF CONTENTS

Preface ..................................................................... ii

Acknowledgments and Availability of Report ........................................... ii

Highlights of the NIOSH Health Hazard Evaluation ....................................... iii

Summary ................................................................... iv

Introduction ................................................................. 1

Background .................................................................. 1

Methods .................................................................... 1

Evaluation Criteria ............................................................. 2

Site Observations .............................................................. 4

Discussion .................................................................. 4

Conclusions ................................................................. 6

Recommendations ............................................................. 6

References .................................................................. 6

Health Hazard Evaluation Report No. 2001-0316-2865 Page 1

INTRODUCTION

On May 21, 2001, the National Institute for

Occupational Safety and Health (NIOSH)

received a request for technical assistance from

the US Environmental Protection Agency (EPA)

regarding a Superfund Site at a former tannery,

Independent Leather, in Gloversville, New York.

The request concerned remediation workers’

potential exposures to biological contaminants

from animal hides, fleshings, and hair, which

were abandoned when Independent Leather

declared bankruptcy in 1994. NIOSH was

specifically asked to evaluate potential employee

exposures during remediation and to recommend

proper remediation guidelines and PPE. No

health effects were reported. In response to this

request, NIOSH investigators conducted a site

visit on June 26-27, 2001. Following the site visit,

recommendations were provided to the EPA via

teleconference.

BACKGROUND

Independent Leather Manufacturing, a tannery

located in Gloversville, New York, operated from

1880-1994. Independent Leather declared

bankruptcy in 1994 and the property was

abandoned leaving behind equipment, files,

chemicals, and processed and unprocessed hides,

fleshings (pieces of skin and fat), and animal hair

of unknown origin. The facility is now a US

EPA Superfund hazardous waste site. It is

situated in a residential area with houses and a

walking path within 50 yards of the property.

The site is unsecured and consists of 2 buildings,

which are readily accessible to the public. The

roof of building 2 has partially collapsed and

flooding has occurred on the ground level of each

building. Homeless people were reported to have

lived in both buildings. 

On June 25, 2001, the US EPA began

preparations to cleanup the former Independent

Leather tannery site. At that time, no

remediation work inside the building had begun.

Initially, the primary focus of the cleanup was

chemical contamination removal, particularly

chromium. However, concerns regarding

exposure to infectious agents from the animal

products and microbial growth arose and

prompted the NIOSH request. Earth Tech, an

environmental remediation and waste services

consultant, was contracted to conduct the

cleanup with oversight by a US EPA on-sc ene

coordinator.

Independent Leather processed animal hides into

leather and suede, which were then sold to

leather products manufacturers to make gloves,

purses, and other leather goods. During the

tanning process, hides were received in building

2 and prepared for the tanning process using

sodium sulfide or an equivalent chemical. Hides

were then sent to building 1 for tanning and

coloring before shipment to other vendors. The

tannery used both domestic and imported hides,

but the types of animals and the country of origin

is unclear. The manner in which these skins

were cured and disinfected prior to shipment is

unknown. While the specific process details are

not available, based on industry standards we can

generalize the activities that took place at the

tannery. The preservation state of the hides or

skins dictates how they are prepared. In

preparation for tanning, the hides were washed

and disinfected, then soaked in lime to loosen the

epidermis and hair roots. Unwanted hair,

proteins, and fats were then removed. Hides

were placed in large tumblers containing a

chromium solution for tanning. The tanned

leather could then be treated with a aniline dye

for coloring.1 

METHODS

The purpose of the site visit was to review the

scope of the project, evaluate work practices, and

discuss strategies to minimize exposures to

biological contaminants. The site visit consisted

of an opening conference, a walkthrough of the

EPA hazardous waste site, and informal

interviews with the EPA site coordinator and

remediation contractor regarding their work

activities and the superfund site. During the

opening conference, we provided information

about NIOSH, reviewed the scope of our
Page 2 Health Hazard Evaluation Report No. 2001-0316-2165

activities, and discussed specific issues and

concerns with meeting participants. Additional

research after the site visit included a literature

search on the biological hazards associated with

tanneries and potential anthrax exposure and

consultation with infectious disease researchers

at the CDC. 

EVALUATION CRITERIA

There is a lack of specific recommendations,

guidelines, or regulatory guidance for worker

protection against infectious agents during

remediation of waste sites such as this tannery.

When assessing workplace conditions where

environmental evaluation criteria have not been

developed or are not applicable, NIOSH field

staff may utilize guidelines and recommendations

developed by public health agencies or

professional associations, accepted industry

practice, or criteria for safe work practices

published by standard setting organizations. In

some situations, workplace evaluations and

recommendations may be based on “state of the

art” industrial hygiene and occupational medicine

concepts, principles, and practices, or by analogy

to other similar settings. Additionally, to assist

with this project, infectious disease and biosafety

experts were consulted. The literature was

reviewed to obtain the most current references.

Note that evaluation criteria may change over the

years as new information on the risk of acquiring

infections, exposure routes, efficacy of control

systems, or safe work practices become

available.

Anthrax

Anthrax, Bacillus anthracis (B. anthracis), is a

large, gram-positive, spore-forming bacterial rod

that is acutely infectious. Anthrax most

commonly occurs in wild and domestic lower

vertebrates such as cattle, sheep, goats, camels,

and antelopes. Humans can become infected

when exposed to infected animals or tissue from

infected animals. Anthrax is also considered one

of the greatest biological warfare threats,

however, this type of anthrax has been

manipulated and is found in higher concentrations

than would be present by inadvertent anthrax

exposures in the environment.2,3

Anthrax infection can occur through three routes:

dermal, inhalational, and gastrointestinal. The

infectious dose for humans has not been

established but it is dependent upon a number of

factors including route of infection, nutritional and

other states of health of the infected person, and

virulence of the particular strain. Symptoms vary

depending on how the infection was contracted.

Dermal exposure to anthrax (cutaneous anthrax)

accounts for approximately 95% of anthrax

infections. Anthrax infection through the skin

occurs when B. anthracis contacts a cut or

abrasion of the skin. The infection begins with a

small red bump which develops into an ulcer with

a black necrotic center. The infection can be

treated with an antimicrobial therapy. Inhalation

of B. anthracis (pulmonary anthrax) can cause

hemorrhage and necrosis of multiple organ

systems and usually results in death. Humans

may also become ill after eating contaminated

meat (gastrointestinal anthrax). Symptoms from

the ingestion of anthrax may include nausea, loss

of appetite, vomiting which is followed by

abdominal pain, vomiting of blood, and severe

diarrhea. Gastrointestinal anthrax results in death

in 25% to 60% of cases.3,4,5 However, anthrax

infection is readily treatable if diagnosed in the

early stages of infection.6

Since 1991 only three cutaneous anthrax

infections have been documented in the United

States.7,8In the United States, only 1 case of

inhalational anthrax has been documented since

1976 and no gastrointestinal anthrax infection has

been documented.8 Retained as spores within

soil, B. anthracis can remain viable for decades

until favorable conditions permit dispersion and

germination. However, the secondary

aerosolization potential for these spores is low

due in part to the clumping potential of spores

with the soil into larger particles. This clumping

characteristic along with the requirement for a

high infectious dose (8,000-10,000 spores) may

explain the rarity of human inhalation infection.2
Health Hazard Evaluation Report No. 2001-0316-2865 Page 3

Microorganisms

Microorganisms (including fungi and bacteria) are

normal inhabitants of the environment. Fungi

comprise 25% of the biomass of earth;9

therefore, human exposure to fungi is ubiquitous.

Although there are thousands of fungal species,

reports of human and animal diseases have

involved fewer than 100 species.9 Saprophytic

fungi(i.e., those utilizing non-living organic matter

as a food source) inhabit soil, vegetation, water,

or any reservoir that can provide an ample supply

of nutrients. Under the appropriate conditions

(optimum temperature, pH, and with sufficient

moisture and available nutrients) saprophytic

microorganism populations can be amplified.

Through various mechanisms, these organisms

can then be disseminated as individual cells or

with soil or dust particles or water droplets. 

Fungi can produce adverse health effects by

three known mechanisms: (1) immunologic

hypersensitivity to the fungus (allergy), (2) fungal

infection (i.e., mycosis), and (3) mycotoxicosis, a

reaction to toxins produced by the fungus.10

Health effects related to allergenic responses are

based, partly, on a genetic predisposition.11

Allergic diseases typically associated with

exposures in indoor environments include allergic

rhinitis (nasal allergy), allergic asthma, allergic

broncho pulmonary aspergillosis, and extrinsic

allergic alveolitis (hypersensitivity pneumonitis).12

Allergic respiratory diseases resulting from

exposures to microbial agents have been

documented in agriculture, biotechnology, office,

and home environments.13,14,15

Acceptable levels of airborne microorganisms

have not been established and no legal regulations

exist for evaluating the potential health effect of

microbial contamination or remediation.

Relationships between health effects and

environmental microorganisms must be

determined through the combined contributions of

medical, epidemiologic, and environmental

evaluation. 16 The current strategy for on-site

evaluation involves a comprehensive inspection of

problem areas to identify sources of microbial

contamination and routes of dissemination. In

those locations where contamination is visibly

evident or suspected, bulk samples may be

collected to identify the predominant species.

However, associating health effects with airborne

microbial contaminants can be difficult.

Personal Protective

Equipment

Protective clothing and equipment are designed to

shield or isolate individuals from the chemical,

physical, or biological hazards that may be

encountered during their work.17 Personal

protective equipment (PPE) is generally

considered the last line of defense, and is utilized

after every effort to eliminate the hazard through

feasible engineering or administrative controls has

been implemented. PPE places the burden of

protection on the employee, and if the equipment

fails, exposure could occur. PPE can be an

effective control technique for occupational

hazards; however, PPE effectiveness depends on

proper use by the wearer.

18 PPE is also

appropriate in some situations as a backup in the

event of an engineering control failure or for jobs

of short duration. Selection of PPE appropriate

for a given task should be made from assessment

of the worksite hazards, which includes an

evaluation of each activity. Hazard assessments

require a good understanding of the work tasks,

knowledge of the potential routes of exposure,

the opportunities for exposure in the task

assessed (nature and extent of worker contact),

and the potential for adverse health outcomes if

exposure were to occur. Accident and incident

reports should be reviewed to identify those

injuries or exposure incidents (whether or not

infection occurred) that could have been

prevented by the proper use of PPE. Most

approaches for selecting the appropriate PPE

incorporate the following process:8

1. Determination of the hazards most likely to

occur

2. Assessment of the adverse effects of

unprotected exposure
Page 4 Health Hazard Evaluation Report No. 2001-0316-2165

3. Identifying other control options that can be

used instead of protective clothing or

equipment

4. Determining the performance characteristics

needed for protection

5. Evaluating the need for decontamination

6. Assessing any constraints that may hinder

the use of PPE (e.g., ergonomic s, safety,

vision, dexterity)

Once it is determined that PPE is required for a

task, its use should be mandatory. PPE should be

individually assigned whenever possible. Written

procedures should be in-place to ensure

consistent selection and use of PPE. Affected

users must be informed of the need for PPE,

consequences of not wearing the appropriate

PPE, and how to properly inspect, wear,

maintain, and store the PPE. Users must also be

informed of all limitations associated with the use

of PPE and must be aware that the equipment

does not eliminate the hazard. Finally, periodic

inspections and evaluations of the PPE program

should be conducted to ensure that procedures

are consistently followed, to identify any process

changes that may have occurred, and that the

selected PPE is still appropriate for the given

task.

SITE OBSERVATIONS

Building 2 is a 2-story warehouse that is located

closest to the public walking path. Building 1 is a

4-story building; its roof partially collapsed during

the 2001 winter, allowing snow to enter the

building. During that winter, the EPA coordinator

reported that 2 to 4 inches of liquid was observed

on the basement floor. The EPA plans to

demolish building 1 after the site clean up

because it is not structurally sound. Visible mold

growth and a musty odor were detected in both

buildings.

In building 2, there are two large open dumpsters

containing unprocessed animal hides, skins, hair,

and fleshings. In addition to the intact hides,

animal hair and parts of the hides were discarded

on the floor. The animal products have been

present since the site was abandoned in 1994.

Many of the hides appear to be deer, which is

most likely of domestic origin. There are also

barrels bearing the label “Product of Ethiopia” in

the building. The manner in which these skins

were cured and disinfected prior to shipment is

unknown. A wastewater characterization study

and engineering report, conducted in 1983,

indicated Independent Leather primarily used

sheepskins from Iran or New Zealand that were

shipped in an acid curing solution. However, no

documentation was found describing the process

at the time the tannery closed in 1994.

Building 1, where most of the tanning operations

took place, contains more hazardous chemicals

than building 2. There is chromium contamination

throughout the building. Stagnant liquid was

found inside some of the wooden tumblers. A

sheepskin with wool was observed on the floor.

Animal hair and small pieces of skins and hides

were also scattered throughout the building. 

The remediation workers at the site are currently

trained in hazardous waste remediation and are

included in a hazard communication and

respiratory protection program. Following the

site visit, the EPA reported constructing an

isolation barrier on the ground floor of building 2

by closing the doors and sealing the windows

with plastic. This area is maintained under

negative pressure and all air exhausted to the

outside is filtered using a high-efficiency

particulate air (HEPA) filter. All remediation

workers were reported wearing full face

respirators with high efficiency particulate filters,

Tyvek® suits, boot covers, gloves, and hard hats.

Animal hides and other by-products are placed in

sealed barrels, which are wiped down with a

bleach solution before shipment to an incinerator.

DISCUSSION

Anthrax is common in southern and eastern

Europe, the Middle East, South and Central

America, and several countries of Africa and

Asia. The US Department of Agriculture’s
Health Hazard Evaluation Report No. 2001-0316-2865 Page 5

(USDA) Animal and Plant Health Inspection

Service (APHIS) restricts the importation of

animals and animal products from countries

where anthrax infections occur. These imported

products must be certified by foreign animal

health officials, quarantined, or cleaned and

disinfected at import centers prior to entry into

the US. Sporadic outbreaks of anthrax infection

have occurred in the US. In August 2000, a

steer was found dead and later slaughtered for

consumption in Minnesota. B. anthracis was

isolated from the steer and the people who

consumed the contaminated meat were treated

with antibiotics, although they were not diagnosed

with anthrax infection. In 1999, 120-150 cattle

died of anthrax in North Dakota. 5 As previously

noted, only three cases of anthrax infection

(cutaneous) have been reported in the United

States since 1991. 

The inhalation hazard of anthrax spores during

this remediation work is minimal based on the

dose necessary for infection and the low

secondary aerolization potential of anthrax

spores.6,19 According to the World Health

Organization (WHO), “substantial exposure is

evidently necessary before risk of inhalation

anthrax becomes significant.”6 The most

common route of anthrax infection in humans is

through dermal exposures, when spores come

into contact with skin abrasions. 

Because importation records are not available to

determine the manner in which the hides, skins,

and other animal products were treated prior to

arrival at the tannery and the origin of the hides

is uncertain, the potential for the presence of B.

anthracis spores at the site and a resulting

exposure to these spores for remediation workers

cannot be ruled out. Some studies suggest that

the de-hairing process, which uses a sodium

sulphide liming mixture with calcium hydroxide,

may kill any spores that were present.20,21 While

the likelihood of exposure is minimal, prudent

precautions should be taken to protect workers

during these activities. No guidelines currently

exist for remediation workers exposed to

biohazards under these circumstances. As such,

the focus for minimizing risk is to reduce the

likelihood of skin exposure through use of PPE

and work practices (i.e., wet method of

decontainment, barrier isolation). 

Decontamination is recommended anytime a

worker has direct physical contact with biological

agents such as anthrax spores. Guidelines for

decontamination of surfaces, PPE, and skin vary

and there is no consensus on the appropriate

method. Effective disinfection of spores is

extremely difficult and may not be achievable.

WHO has guidelines on decontamination but

suggests that these be tailored to specific

situations.6 WHO suggests disinfecting surfaces

with a three-stage approach: (1) disinfecting

surfaces with either a 10% formaldehyde or 4%

glutaraldehyde solution for 2 hours; (2) cleaning

with hot water to remove any debris; and (3) final

disinfection using either 10% formaldehyde, 4%

glutaraldehyde, 3% hydrogen peroxide, or 1%

peracetic acid with a 2-hour contact time.

Incineration or autoclaving are recommended for

contaminated clothing or tools. WHO

recommends soaking miscellaneous nondisposable items overnight in a 4% formaldehyde

solution or 2% glutaraldehyde. However, the use

of these chemicals involves an occupational risk

to workers which should be considered before

use. 

Decontamination of PPE using a bleach solution

(sodium hypochlorite) is mentioned as the

disinfectant of choice by other sources. 4 It is

important to note that bleach is sensitive to pH

such that inactivation of spores is inhibited at

alkaline pH. Using hypochlorite in solution

(around room temperature) without adjusting the

pH of the solution to neutral or acid could result

in an overestimation of its sporicidal

effectiveness.22 In general, the effectiveness of

decontamination procedures to inactivate spores

is still in question. 

In the event of PPE failure resulting in skin

contact with anthrax, recommendations for

cleaning and disinfecting the skin vary. Copious

soap and water washing of the skin that is

contacted by anthrax has been recommended.23

Other recommendations include wiping grossly

contaminated skin areas with 0.25 to 0.5%

hypochlorite, followed by thorough soap and
Page 6 Health Hazard Evaluation Report No. 2001-0316-2165

water washing.24 Regardless of decontamination

procedures, there is consensus on the importance

of post-exposure surveillance by health care

professionals and any skin lesions developing

after exposure should be immediately reported to

a physician.

The growth and survival of microorganisms in

environmental reservoirs require: (1) a suitable

nutrient source; (2) adequate available water; and

(3) an appropriate temperature. These

c onditions, when combined with high porosity

materials, are optimum for microbial growth. In

both buildings at this site these conditions were

present; i.e., water intrusion from snow melt and

rain storms, organic material in the dirt floors and

dumpsters, and cool temperatures. Microbial

contamination was visually apparent in various

locations including the wooden tumblers, beams,

and stagnant water reservoirs. An odor,

attributable to microbiological growth, was

strongly present in both buildings. Given the

extent of microbial contamination, the microbial

reservoirs will unavoidably be disturbed and

disseminated during remediation. It is important

that all remediation activities be conducted with

an awareness of the potential bioaerosol

exposures and with minimal disturbance of

contaminated materials. Under these conditions,

isolation barriers are necessary to contain

airborne spores and other biological matter.

Barriers alone disrupt the pathways between

remediation zones and adjacent environments, but

disseminated aerosols almost invariably find

breaks in any barrier system. Therefore,

negative pressure relative to adjacent areas is

recommended to ensure containment. It is

critical that the exhausted air streams be

appropriately filtered using a HEPA filter to

guard against re-entry of microbially

contaminated air back into the zone of

remediation and/or to other areas that are

considered uncontaminated. EPA personnel

indicated such barriers and ventilation systems

were constructed following the NIOSH visit.

While remediation workers generally have

extensive training on hazards associated with

chemical exposures, most do not have experience

with biological hazards (anthrax or other

microorganisms). PPE procedures established at

the site to deal with the chemical hazards, in

addition to decontamination and containment

procedures, should be sufficient to protect

workers from the potential biological hazards at

this site.

CONCLUSIONS

The likelihood that anthrax spores are present is

minimal at this tannery, however the presence of

spores cannot be ruled out and appropriate

precautions are warranted. The potential for

inhalation exposure is minimal, therefore the

primary concern for workers is dermal contact

during remediation activities. There is a lack of

specific recommendations, guidelines, or

regulatory guidance describing safety and health

criteria for worker protection during remediation

of waste sites such as this tannery. The

conditions for the growth and survival of

microorganisms were present in both buildings,

and visible mold growth was observed. Based on

discussions with EPA personnel on work

practices and PPE use, the precautions taken by

remediation workers are prudent and appropriate

and should adequately prevent exposure to

biological hazards.

RECOMMENDATIONS

Based on our evaluation, the following

recommendations are provided. These address

PPE usage, appropriate training, and work

practices to reduce exposures to bioaerosols

during remediation.

1. Personnel should continue to wear full-face

respirators with a dual high efficiency particulate

air filter and organic vapor cartridge, disposable

protective clothing covering the head and shoes,

and gloves during remediation activities. The

respirator will ensure workers are protected from

the inhalation hazard of bioaerosols. The PPE

will prevent dermal exposures to spores in the

rare instance that anthrax is present. 
Health Hazard Evaluation Report No. 2001-0316-2865 Page 7

1. Encyclopedia of Occupational Health and

Safety. Tanning and Leather Finishing 88.2-88.4.

2. Cieslak TJ, Eitzen EM [1999]. Clinical and

Epidemiologic Principles of Anthrax. Emerging

Infectious Diseases. 5(4): 552-555.

3. NCID Anthrax Disease Information

www.cdc.gov/ncidod/dbmd/disease.

4. NIOSH [1986]. Occupational Respiratory

Diseases. Cincinnati, OH: U.S. Department of

Health and Human Services, Public Health

Service, Centers for Disease Control, National

Institute for Occupational Safety and Health,

DHHS (NIOSH) Publication No. 86-102.

5. CDC. Human Ingestion of Bacillus

Anthracis-Contaminated Meat- Minnesota,

August 2000. MMWR 2000, 49(36):813-6.

6. WHO [1998]. Guidelines for the

Surveillance and Control of Anthrax in Humans

and Animals. Geneva, Switzerland. World Health

Organization. Publication No. WHO/EMC/ZDI

98.6.

7. Brachman P, Kaufmann A. Anthrax. In:

Evans A, Brachman P, eds. [1998]. Bacterial

infections of humans. New York, New York:

Plenum Medical Book Company.

8. CDC. Human Anthrax Associated with an

Epizootic Among Livestock- North Dakota, 2000.

MMWR 2001, 50(32):677-680.

9. Miller JD [1992]. Fungi as contaminants in

indoor air. Atmosph Environ 26A(12):2163-72. 

10. Tulisjj, Stopford W [1994]. General

Principles of Microbiology and Infectious Disease

In: Wald PH, Stave G, eds. Physical and

Biological Hazards of the Workplace. New

York, NY: Van Nostrand Reinhold: pp. 237-42.

11. Pickering CA [1992]. Immune respiratory

disease associated with the inadequate control of

indoor air quality. Indoor Environment 1:157-61.

12. Molhave L, Back B, Pedersen OF [1986].

Human reactions to low concentrations of volatile

organic compounds. Environ Int 12:167-76.

2. Remediation workers should be trained on

proper clean up methods, proper PPE, and

potential health hazards associated with

exposures to molds and anthrax. Workers should

be trained to seek treatment with a health care

professional if they suspect infection. This

training should be done in compliance with the

OSHA Hazard Communication Standard (29

CFR 1910.1200), and the Hazardous Waste

Operations and Emergency Response Standard

(29 CFR 1910.120).

3. Workers who have direct skin contact should

immediately wash their hands vigorously with

soap and water. If workers observe any skin

lesions or other medical problems subsequent to

direct contact, they should seek medical

treatment by a health professional. 

4. All wastes potentially contaminated with

anthrax spores (e.g., hides, skins, and any other

animal products) should be considered hazardous.

PPE such as disposable protective clothing should

be also be considered hazardous. This waste

should be placed in a waste container and safely

transported to a site for incineration.

5. To suppress the dust, hair, and microbial

contamination, the surfaces should be misted with

water prior to remediation work. Non-porous

(e.g., metals, glass, and hard plastics) and semiporous (e.g., wood and concrete) materials can

be cleaned and reused. Cleaning should be done

using a detergent solution or a 5-10% bleach

solution. Porous materials such as wallboards

and insulation should be removed in a sealed

plastic bag and discarded. There are no special

requirements for the disposal of moldy materials.

REFERENCES
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13. Vinken W, Roels P [1984]. Hypersensitivity

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19. Ashford D [2001]. Telephone conversation

on June 29, 2001, between L. Delaney, AFO,

NIOSH, CDC, and D. Ashford, NCID, CDC.

20. Lindner F, Bohm R. [1985]. Effect of lime

on spores of Bacillus anthracis in the sludge of a

treatment plant connected with some tanneries.

In: Strauch D, Havelaar AH, Hermite PL (eds)

Inactivation of Microorganisms in Sewage Sludge

by Stabilisation Proc esses. London, England:

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21. Robertson ME [1948]. Micro-organisms

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agents. App Envir Micro 62(2):545-551.

23. CDC. Bioterrorism Alleging Use of Anthrax

and Interim Guidelines for Management- United

States, 1998. MMWR 1999, 48(04):69-74.

24. Kauffman A [1999]. Email communication

of July 19, 1999, between A. Kauffman,

Emergency Response Coordination Group,

NCEH, CDC, and EK Gray, Emergency

Preparedness and Response Branch, Division of

Emergency Environmental Health Services,

NCEH.
Health Hazard Evaluation Report No. 2001-0316-2865 Page 9
For Information on Other

Occupational Safety and Health Concerns

Call NIOSH at:

1–800–35–NIOSH (356–4674)

or visit the NIOSH Web site at:

www.cdc.gov/niosh

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