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Pepper Spray too Dangerous for DOC Training?
In September of 1996, Paul M. Sullivan, health compliance officer for the North Carolina Department of Labor sent a letter to Mr. Franklin Freeman of the North Carolina Department of Correction (DOC). An alert reader obtained a copy of this letter and forwarded it to PLN's editors, who have verified its authenticity. We publish the full text of the letter here:
OSH [Occupational Safety and Health] Inspection #125226902, initiated April 22, 1996, at the Mecklenburg Correctional Center, is officially being closed. The investigation found that although exposure to Oleoresin Capsieum (OC) spray [i.e. pepper spray] is an important training activity, a direct (full-face) exposure poses a health risk. This finding differs from the OSH Division's initial assessment in April of 1994 of the potential effects of the training program. Consistent with the commitment made at that time, no citation is being issued for a violation of the OSH Act as a result of the Department of Correction's implementation of the program. However, based on this information as we discussed with you on July 26, 1996, we recommend a review and modification of your program. We appreciate your letter of August 5, 1996, indicating that you are re-evaluating alternatives to full exposure training and urge you to proceed. The following are our recommendations:
1) The use of direct exposure should be changed to an indirect one, such as spraying a wall above each trainee's head.
2) A medical screening program should be established to identify those employees with health conditions that may be exacerbated by any exposure to the OC spray. Additionally, the initial evaluation of accommodation requests should be conducted by a trained health professional.
3) Hazard communication training should be improved, specifically including a discussion of health effects experienced by DOC employees during direct exposure.
4) Water hoses utilized during decontamination should be mounted so that trainees will have full use of both hands to assist in keeping their eyes open.
5) Exposure training during cold weather should be minimized or moved indoors to reduce the possibility of hypothermia during decontamination.
The implementation of these items should decrease the number and severity of OC spray-related training injuries. We would appreciate your notifying us when your review is complete and what modifications to your program you adopt. If you have any questions, please give me a call. Thank you.
PLN contacted Mr. Freeman of the North Carolina DOC to ask what changes, if any, have been made to DOC policies related to exposure of prisoners to OC (pepper) spray. He failed to respond.
OSH [Occupational Safety and Health] Inspection #125226902, initiated April 22, 1996, at the Mecklenburg Correctional Center, is officially being closed. The investigation found that although exposure to Oleoresin Capsieum (OC) spray [i.e. pepper spray] is an important training activity, a direct (full-face) exposure poses a health risk. This finding differs from the OSH Division's initial assessment in April of 1994 of the potential effects of the training program. Consistent with the commitment made at that time, no citation is being issued for a violation of the OSH Act as a result of the Department of Correction's implementation of the program. However, based on this information as we discussed with you on July 26, 1996, we recommend a review and modification of your program. We appreciate your letter of August 5, 1996, indicating that you are re-evaluating alternatives to full exposure training and urge you to proceed. The following are our recommendations:
1) The use of direct exposure should be changed to an indirect one, such as spraying a wall above each trainee's head.
2) A medical screening program should be established to identify those employees with health conditions that may be exacerbated by any exposure to the OC spray. Additionally, the initial evaluation of accommodation requests should be conducted by a trained health professional.
3) Hazard communication training should be improved, specifically including a discussion of health effects experienced by DOC employees during direct exposure.
4) Water hoses utilized during decontamination should be mounted so that trainees will have full use of both hands to assist in keeping their eyes open.
5) Exposure training during cold weather should be minimized or moved indoors to reduce the possibility of hypothermia during decontamination.
The implementation of these items should decrease the number and severity of OC spray-related training injuries. We would appreciate your notifying us when your review is complete and what modifications to your program you adopt. If you have any questions, please give me a call. Thank you.
PLN contacted Mr. Freeman of the North Carolina DOC to ask what changes, if any, have been made to DOC policies related to exposure of prisoners to OC (pepper) spray. He failed to respond.
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