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The highly addictive, synthetic opioid fentanyl remains the deadliest drug threat in America and is infiltrating our schools at alarming rates. With a potency 50 times greater than heroin and 100 times greater than morphine, just two milligrams of fentanyl, a small amount that fits on the tip of a pencil, is considered a potentially deadly dose.
The good news is safe practices for handling drugs in the workplace have improved since OSHA first published guidance in 1986. However, performance enhancing and mass-produced drugs like fentanyl, methamphetamines, and other hazardous drugs are enticing students at breakneck speed. These drugs creep into schools either by posing as prescription medications or by being brought in intentionally for recreational use. Regardless of entry route of hazardous drugs into schools, educational employers must recognize the risk of serious illness and death not only to students but also to teachers and staff that work in school settings.
Scope
Public school districts are not subject to federal OSHA but may be covered by OSHA-approved state plans. State plans may incorporate OSHA standards by reference or establish their own standards that are at least as effective as federal OSHA. Private schools, however, are considered employers under the OSH Act and are subject to federal OSHA jurisdiction. If covered by OSHA or OSHA-equivalent regulations, educational employers must protect employees from recognized, serious hazards, such as hazardous drugs.
Regulatory citations
- 29 CFR 1904 — Recording and reporting occupational injuries and illnesses
- 29 CFR 1910 Subpart I — Personal protective equipment (PPE)
- 29 CFR 1910.120 — Hazardous waste operations and emergency response
- 29 CFR 1910.141— Sanitation
- 29 CFR 1910.151 — Medical services and first aid
- 29 CFR 1910.1020 — Access to employee exposure and medical records
- 29 CFR 1910.1200 — Hazard communication
- 29 CFR 1910.1450 — Occupational exposure to hazardous chemicals in laboratories
- 29 USC 654 — General duty clause of the OSH Act
Key definitions
- Fentanyl: A potent, synthetic opioid drug approved by the Food and Drug Administration (FDA) for powerful pain relief but can also have significant addictive tendencies.
- Methamphetamine: A potent, highly addictive stimulant that affects the central nervous system to increase energy and produce euphoric sensations.
- Opioid: A class of drug used to reduce moderate to severe pain. Opioids include legal drugs such as oxycodone, hydrocodone, and morphine as well as illegal drugs like heroin.
Summary of requirements
Protecting workers in educational settings from drug hazards requires:
- Keeping exposures as low as reasonably achievable (ALARA) through continuous monitoring and transparent dialogue with workers about ever-evolving hazardous drugs;
- Establishing and communicating policies and procedures required for risk control and emergency response for possible drug overdoses or potentially violent drug-related situations;
- Investigating any incidents or near misses involving that may indicate remediations are needed that would further protect workers; and
- Training employees to recognize hazardous drugs in the educational setting, the hazards and effects of drug use, and required protective measures.
Educational employers also should also:
- Conduct a hazard assessment(s) to identify the risk and protective factors that increase or decrease the potential for substance misuse and its consequences, and the factors that could be modified through interventions;
- Engage employees in the development of a safety and health plan to ensure they are aware of risk factors and comply with protective measures;
- Encourage open and honest communication about drug use or abuse in schools so remediations can be made;
- Collaborate across public and private sectors to develop and evaluate interventions that address the social, environmental, or economic determinants and consequences of hazardous drugs;
- Support effective prevention, treatment, and recovery efforts for users;
- Regularly review and evaluate hazardous drug used in schools (prescribed or recreational)and practices used to reduce exposure; and
- Seek input from affected workers regarding safety concerns so policies and procedures can be updated accordingly.