Carson City Health and Human Services cited by OSHA for potential chemical exposure, lack of necessary training

Since the 1980s, Carson City Health and Human Services has been undertaking mosquito abatement to stem the flow of potential mosquito-borne diseases.

However, it was determined that for many years — and possibly even decades — CCHHS hasn't had a Hazard Communication Plan, which is meant to provide proper training to employees on handling dangerous or toxic chemicals. Without training, this could mean that employees may have been exposed to dangerous chemicals as part of the abatement program.

The OSHA investigation began and notice was received by CCHHS in August 2023, according to CCHHS Director Nicki Aaker, and training on the Hazard Communication Plan was provided on Aug. 16, 2023.

According to OSHA, it requires “all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.”

According to Aaker, the OSHA complaint stemmed from an aerial treatment performed via helicopter on July 17, 2023. Two CCHHS employees assisted with the loading of chemicals into the helicopter, exposing them to the chemicals for around 15 minutes each.

The chemicals had been stored in a shed prior to their transport, and the OSHA citation indicated that CCHHS did not assess the shed to determine if hazards were present that would have necessitated the use of PPE.

However, she said PPE is and always has been available to employees in the Environmental Health Division at all locations of CCHHS, including the mosquito abatement shed.

As part of the investigation, CCHHS received three violations categorized as "serious," which, after a settlement, was categorized to two "serious" and one "other." The initial penalty was $9,042, which as been downgraded to $6,028, which is outlined in the online report.

Unlike other OSHA reports that can be found online, there is no additional data on exactly what the violations were in regards to, presumably as part of the settlement, but instead are only listed as code numbers.

One code violation under "general requirements" indicates all employees must be provided with adequate PPE including protective equipment for eyes, face, head, extremities, protective clothing, respiratory devices, etc.

The second, 1910.120(e) indicates all employees exposed to hazardous substances shall receive training, and the third, 1910.120(h) discusses the need for monitoring when "there may be a question of employee exposure to hazardous concentrations of hazardous substances."

In response to this violation, CCHHS conducted a formal assessment of the mosquito abatement shed which was documented in a hazard assessment form provided by OSHA.

“The OSHA citation also indicated that there was no written hazard communication program and that the employees involved in the mosquito abatement program did not receive effective information and training on the chemicals they were using for mosquito abatement,” Aaker wrote.

However, she said, all employees involved with the abatement program were “seasoned employees with relevant experience” and had access to safety data regarding the chemicals they were handling.
 
After the OSHA violation, CCHHS conducted a formal training with these data sheets to review each chemical involved with employees and created a written record of the training, according to Aaker.

“The OSHA inspection conducted in response to the complaint revealed that Carson City has exhibited good faith in the investigation and there were no instances of repeated, willful, failure-to-abate, or high gravity serious violations,” Aaker said. “HHS abated the violations immediately, within the timeframe provided by OSHA.”

Mosquito Abatement

The Mosquito Abatement Program began in Carson City in the 1980s, which consists of aerial applications each spring and into summer.

These applications are granules of chemicals over larger areas of wetland habitats including Empire Ranch Golf Course, Old Buzzy’s Ranch, the Linear Ditch and Riverview Park. The treatments are slow release and provide approximately 21 days of coverage.

According to Aaker, CCHHS has conducted abatement activities once or twice a month for approximately four months each year, which is handled by one or two members of the Environmental Health Division, which lasted approximately one hour.

The city also uses non-chemical abatement solutions such as the breeding of mosquito fish, which are used in “appropriate areas” on city-owned property.

In Northern Nevada, there are a few mosquito control products that are typically used, including the gradual bacterial larvicide VectoLex FG, which provides 21 days of coverage and targets mosquito larvae before they can become adults.

As of at least 2019, VectoLex FG was the product being used by the city.

According to VectoLex FG’s hazard statements, the chemical is harmful if absorbed through the skin, or inhaled and PPE should be utilized to avoid contact with skin, eyes or clothing. This includes protective eyeware, and a dust/mist filtering respirator of at least N-95 standards.

The hazard statement indicates that repeated exposure to high concentrations can cause allergic sensitizations.

The statement also gives specific advice for what to do in case of exposure in eyes, skin, or inhalation, all of which include immediately calling poison control and removing the substance when possible from their person.

However, Aaker said that “the product that was used … is not considered carcinogenic because of the product’s physical form.”

When asked to confirm VectoLex was the product used, however, the city's Public Information Officer Stephen Wood stated the chemical used is called Altosid. When asked if this was a recent change, since VectoLex was used recently, Wood did not respond.

Aaker said the helicopter pilot, who was on scene during the loading of the abatement chemical, reported that no dust was generated while the chemical was loaded into the hopper.

The day before application, Aaker said, employees were given verbal and written guidance which included “take gloves, prepare as there might be flying environmental contaminants…” but made no mention of the potential hazards of inhaling or allowing the substance on the skin or eyes.

In a 2021 Carson City Integrated Pest Management Program packet, it outlines a number of methods and requirements needed for Integrated Pest Management (IPM) and abatement programs, including “adequate training for staff and a minimum of one Maintenance Coordinator and the Senior Natural Resource Specialist will be trained as a Nevada Pest Control Government Licensed applicator charged with coordinating training.”

When asked about this packet, and whether or not these individual employees ever received their licensure, City Manager Nancy Paulson said the mosquito abatement program does not fall under the umbrella of the other pest management and abatement programs, as those are handled by the Carson City Parks, Recreation and Open Space department. While Parks and Recreation employees do have their licensures and provide training as outlined in the BeeCity packet, the mosquito abatement program is only under Health and Human Services.

Under Health and Human Services, Division Manager Dustin Booth holds the licensure, but according to Wood, the city did not know this training was required until OSHA got involved:

The City was not aware that specific training on the chemicals used in mosquito abatement was required until OSHA became involved. The OSHA violation was related to lack of adequate training on the materials that were used not on how to conduct mosquito abatement. According to OSHA regulations, the employees who handle certain hazardous chemicals must receive training about these chemicals at the beginning of their employment and when a new chemical is introduced. This training consists of a review of the written hazard communication plan, the safety data sheets, labels etc., and the City is currently in compliance with this requirement.

At this time, Wood said that “to his knowledge and based on the information that current management has, there have been no employee complaints related to the mosquito abatement program.”