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       Hazards, number 151, 2020
INFECTIONS. They were warned. They knew what to do. They did nothing.
Long before Covid-19, unions made repeat warnings about the need to prepare for ‘emerging threats’. Hazards editor Rory O’Neill exposes the decades of inaction that paved the way for the pandemic and left us without a workplace biohazards law.


No-one was prepared. Covid-19 was unforeseen, bigger and more deadly than anyone could have anticipated. We didn’t know how to respond, but reacted quickly to limit the harm from what became the biggest workplace killer of modern times.

As politicians and their advisers wrote, tweaked and rewrote guidance, they maintained they were responding to emerging science, dealing with ‘unknowns’.

It is a fatalism that sits uneasily alongside the facts. The warnings had been repeated over decades. There had been agreements that global rules were necessary.

They were just never acted on.

Lost generation

It makes for a damning timeline. It starts with a resolution at the 1993 International Labour Conference – a meeting of governments and employers’ and workers’ organisations at the International Labour Organisation (ILO). This called on ILO to prepare a biological agents standard. Then the process at the UN agency stalled.

In November 1999, ILO’s governing body deferred an agenda item concerning “possible instruments on the prevention of biological hazards at work” until after the adoption of a code of practice on this subject.

In 2007, an ILO meeting of experts on hazardous substances concluded the complexity of biological agents meant it needed its own, separate rules.

At both 2017 and 2018 meetings reviewing ILO’s health and safety conventions and any gaps, unions called for a new convention on biological hazards and got agreement this should be part of ILO’s rule making plan.

The code of practice has yet to appear. The first draft of an ILO biological agents guide, in preparation for over a year, has yet to see the light of day, and ILO is refusing to answer questions about its whereabouts.

Instead, in 2020, ILO again deferred a discussion on a biological hazards rule. ILO said this was necessary because of the Covid pandemic.

We warned them

Unions have issued serial warnings and calls for action, in the presence of ILO experts, governments and employers’ representatives, about the real and present threat from biological hazards.

HUMAN COST  Recent work-related biological diseases in the UK include a case of cow pox in a 15-year-old who had been feeding calves and several cases of gastrointestinal disease in workers treating sick lambs in a pet shop. The consequences can be more serious. Hot tub firm JTF Warehouse was fined £1m in 2017, after delivery driver Richard Griffin, 64, developed Legionnaire’s disease and died after making a drop at the premises. And Craig Barratt, 16, a volunteer at an animal charity, died from Weil’s disease.  A 2017 inquest heard the Molton College animal welfare student developed the condition after contact with animal urine.

It is a big problem. ILO estimates 16 million workers worldwide are at risk from biological agents, in sectors as diverse as agriculture, pharmaceuticals, chemicals and health care.

There’s the emerging workplace risk from antimicrobial resistant ‘superbugs’ encountered in health care or in agriculture and meat processing. Then there’s the incidental exposures at work, which could cause conditions including gastrointestinal disorders and Hepatitis A from bad practices like sewage dumping on rail lines, or Toxocariasis, Psittacosis or Histoplasmosis from contact with animal or bird droppings.

There’s also the risks from exposure to highly contagious communicable diseases like chicken pox or measles in schools, health care or other work settings. Or infections from injuries caused by needles or sharps used at work or encountered accidentally in cleaning or other jobs. Or exposure to enzymes used in products like biological washing powders.

The union warnings have been explicit. At both the 2017 and 2018 ILO standards review meetings, unions name-checked recent work-related outbreaks including:

•  Viral conditions like SARS, Middle East Respiratory Syndrome (MERS – another ‘novel’ coronavirus), Avian influenza virus (Bird flu), Swine flu, Zika virus, Ebola and West Nile virus;
•  Tick-borne diseases like Monkey fever and Lyme disease;
•  Bacterial conditions like MRSA, Anthrax, Brucellosis, Leptospirosis (Weil’s disease), Psittacosis, Legionnaire’s disease and Q-fever;
•  Blood borne diseases like HIV and Hepatitis B and C; and
•  Mould or fungal spore related conditions like Histoplasmosis and Extrinsic Allergic Alveolitis (eg. Farmer’s lung).

The union argument referred explicitly to the need “to prepare for emerging threats.” As Covid-19, a Severe Acute Respiratory Syndrome (SARS) caused by a coronavirus (SARS-CoV-2), made horribly apparent, these emerging threats can affect the entire workforce and the community at large.

Coronavirus 1.0

It was another outbreak caused by a coronavirus in 2003 – then known simply as SARS – that should have set alarm bells ringing. This SARS outbreak was on the union red flags list presented to ILO in 2017. It killed 8,000 in 26 countries, with the World Health Organisation (WHO) noting: “Most cases of human-to-human transmission occurred in the health care setting, in the absence of adequate infection control precautions.”

DANGEROUS SPECIMEN  Covid-19 isn’t the only biological hazard to workers. The UK workplace safety regulator, the Health and Safety Executive (HSE), says “all diseases” related to biological exposures at work must be reported and over 20 qualify for government industrial disease compensation [more].

Over 1-in-5 of all the cases in the 2003 outbreak were in health care workers – the figure was 43 per cent in Canada - although other work groups were also at risk.
This prompted big questions about the adequacy of protection for workers in the event of other outbreaks.

A March 2004 ILO working paper noted: “Although the national and international response to SARS in 2003 was effective in controlling the disease, new issues, problems and questions have inevitably been raised by the new challenges that SARS, or other similar infections, could present.”

It recommended for SARS workplace infection controls more stringent than those used subsequently for the far more deadly Covid-19 strain, including high performance respirators rather than medical masks for all those working with affected patients. It noted: “It would be ethically unjustifiable to request workers to care for suspect SARS cases without suitable personal protective equipment (PPE).”

That was SARS-CoV-1. When SARS-CoV-2 – Covid-19 – came along, WHO admitted in 5 June 2020 guidance it weakened the PPE requirements because governments were not prepared to offer the good stuff.


Hazards infections webpage.
Hazards coronavirus webpage.
TUC coronavirus resources.
Pandemic flu – advice for union reps, TUC, 2009.
NEU guide to infectious diseases in schools.
Unite coronavirus guide.
GMB guide to coronavirus rights at work.
UNISON guide to coronavirus rights at work.
UNISON MRSA information sheet.
Prospect zoonotic infections fact card.
IUF biological hazards factsheet.
Antimicrobial Resistance (AMR) - A Workplace Hazard, IUF, 2018.
Biological hazards, ILO Encyclopaedia of Occupational Safety and Health.
Biological agents, US OSHA.
HSE infections webpage.
Approved list of biological agents, HSE.
OSH Wiki: Biological agents.
Work-related diseases from biological agents, European Agency for Safety and Health at Work (EU-OSHA).
Biological agents and work-related diseases: results of a literature review, expert survey and analysis of monitoring systems, European Agency for Safety and Health at Work (EU-OSHA), November 2019.
Biological agents and pandemics: review of the literature and national policies, European Agency for Safety and Health at Work (EU-OSHA), 2009.
Nellie J Brown. Communicable Diseases and the Workplace, Cornell University ILR School, 2019.
SARS - Practical and administrative responses to an infectious disease in the workplace, ILO, March 2004.
Q fever website.
Summary report, Prevention and management of sharps injuries: Inspection of NHS organisations and sharps injuries webpages, HSE.
World Health Organisation Zika factsheet.
Ebola (Ebola Virus Disease): Information for healthcare workers, US CDC.
Ebola Virus Disease: Occupational Safety and Health - joint WHO/ILO briefing note for workers and employers, 26 August 2014.

Exposed at work in the UK

When Covid-19 struck, the lack of preparation came at a high cost. Because the necessary PPE wasn’t in place, workers on the frontline were poorly protected.

A third of workers in the UK were considered ‘key workers’.  Even under full lockdown, health and social care were joined by millions of others – almost 70 per cent of these essential workers worked outside of the health and social care sectors – in workplaces that were at best inadequately prepared. 

When the next Covid comes along, we know millions would again be instructed to go to work.  We also know now the workplace is likely to top the list of places they could be exposed. However, the UK system can’t even count the numbers. The RIDDOR reporting regulations have in all probability missed most work-related cases, and several hundred and possibly thousands of deaths.

And the workplace safety regulator, the Health and Safety Executive (HSE) – vandalised by Conservative government cuts and rule changes that saw its proactive inspections drop by 80 per cent in its decade in power – offered little protection. At first HSE suspended all inspections. Then it moved to a system based at least in part on virtual scrutiny.

HSE was anyway enforcing a biological agents law that doesn’t exist. As an afterthought, the hazardous substances law COSHH – which was originally the UK’s interpretation of the EU’s chemical agents directive – was retrofitted to include biological agents like moulds, viruses and bacteria.

It is a poor fit.  The law and the system need fixing.

If not, we risk the next – inevitable - ‘emerging threat’ being every bit as deadly.

Reportable under RIDDOR

The HSE’s reporting regulations RIDDOR require employers to report several categories of biological agent-related occupational diseases or dangerous occurrences.

•  Biological agents  “All diseases and any acute illness needing medical treatment must be reported when it is attributable to a work-related exposure to a biological agent,” HSE says. It adds this includes “a micro-organism, cell culture, or human endoparasite which may cause infection, allergy, toxicity or other hazard to human health.”

•  Specific infections  HSE makes explicit reference to these conditions being reportable when work-related: Anthrax, Zoonoses (animal diseases transmitted to humans), Bovine spongiform encephalopathy (BSE); Influenza, Legionella; Severe acute respiratory syndrome (SARS); and Covid-19.

•  Occupational asthma  Many cases of work-related asthma are caused by biological agents, for example flour, shellfish, animal dander, proteolytic enzymes, and wood dust.

A-Z of eligible diseases caused by biohazards

The Industrial Injuries Disablement Benefit scheme covers work-related cases of:

Allergic rhinitis (tea and coffee processing; contact with other natural products like grain and flour, wood dust and castor or soy bean dust; animals and insects; crustaceans or fish; natural rubber);
Anaphylaxis (natural rubber);
Asthma (any biological asthmagen where work-relatedness can be demonstrated);
Avian or Ovian chlamydiosis (Psittacosis caused by exposure to infected birds or sheep);
Byssinosis (caused by cotton/flax dust);
Cancer of the nose or nasopharynx (wood or leather);
Extrinsic allergic alveolitis (mould or fungal spores. Farmer’s lung);
Hepatitis A (contact with raw sewage);
Hepatitis B and C (human blood of other body fluid exposures);
Leptospirosis (Weil’s disease);
Lyme disease;
Q fever (work with animal remains or products);
Streptococcus suis (contact with infected pigs or pork products);
Tuberculosis (TB).

UK prescribed occupational diseases list


Top of the page






Long before Covid-19, unions made repeat warnings about the need to prepare for ‘emerging threats’. Hazards editor Rory O’Neill exposes the decades of inaction that paved the way for the pandemic and left us without a workplace biohazards law. .

Lost generation
We warned them
Coronavirus 1.0
Exposed at work in the UK
Reportable under RIDDOR
A-Z of eligible diseases caused by biohazards

Hazards webpages
Hazards news
Work and health

See the dedicated Hazards coronavirus resources pages.