- Incidents in which 3 or more visitors, employees, or volunteers have similar symptoms or illness,
- Single reports of rare or reportable diseases (see this list),
- Incidents that result in death, cause serious injury or illness, and/or lead to overnight hospitalization,
- Wildlife encounters of concern, such as bites, scratches, or attacks
- Wildlife deaths that do not fit known patterns. Many infectious diseases affect both humans and wildlife, and some diseases are transmitted from wildlife to people (zoonotic diseases).
Specific investigative actions the OPH might assist with include the following:
Verifying the diagnosis. OPH staff will coordinate and lead discussions with local/state health departments and the CDC. Test results will be reviewed and, if needed, requests will be made for additional confirmatory testing. In-depth interviews will be conducted with cases to determine if a park is the likely source of exposure. This step can take time and is an important sorting process to determine if reported cases are true cases and/or park-associated events.
Finding additional cases. OPH and park staff may use questionnaires, interviews with contacts of cases, and queries of local clinics to identify other visitors or employees with similar symptoms.
Identifying risk factors for illness. Patterns suggesting which populations are at risk may be identified by analyzing detailed information on cases. Sometimes, additional studies are necessary (e.g., studies comparing differences between people who were sick and people who were well; environmental sampling; disease testing in wildlife).
Implementing control measures—Based on presumed or laboratory-confirmed diagnoses, recommended prevention and control measures will be implemented. During this stage of the investigation, the situation is frequently re-assessed to see how well control measures are working and if additional interventions are needed. Common control measures include providing educational materials and emphasizing actions people can take to decrease risk. Occasionally, more aggressive control measures are considered (e.g., prophylactic antibiotics or vaccines; park closure); such interventions will be implemented only after careful consideration of the facts and consultation with park managers, OPH staff, and local/state health authorities.
Disseminating findings. Throughout the investigation, OPH staff will communicate key findings (e.g., briefing statements) to park, region, and WASO managers; OPH staff can also assist with developing, reviewing, and disseminating educational materials and media communications.
Improving Prevention. Disease transmission and outbreak response investigations are conducted in a no-fault approach with a central goal of learning from the event to improve long-term prevention; if warranted, findings may be translated into service-wide actions and scientific publications.
National Park Service Office of Public Health Authorities
The OPH is primarily staffed by Commissioned Corps Officers (Officers) of the United States Public Health Service (USPHS). It functions in many ways like an internal health department, to prevent and detect disease transmission and to promote healthy behaviors. Officers of the USPHS provide assistance to the NPS under the authority of the Public Health Service Act of 1944, codified as amended in various sections of 42 U.S.C. ch. 6A, which grants the Secretary of Health and Human Services (HHS) the authority to ‘encourage, cooperate with, and render assistance to other appropriate public authorities, scientific institutions, and scientists in the conduct of, and promote the coordination of, research, investigations, experiments, demonstrations, and studies relating to the causes, diagnosis, treatment, control, and prevention of physical and mental diseases and impairments of man.’ Id. § 241(a). Additionally, 42 U.S.C. § 300kk: Data collection, analysis, and quality renders authority for the USPHS officers assigned from HHS to DOI to conduct data collection and analysis to mitigate or eliminate disease transmission.The following documents provide additional guidance for the NPS’s public-health program:
NPS Management Policies 2006 § 184.108.40.206 states that the NPS’s public-health program ‘will use the consultation services of commissioned officers of the U.S. Public Health Service.’
The National Park Service’s Director’s Order #83 assigns the NPS Public Health Program with roles of prevention, control, and investigation of food-, water-, vector-borne, and occupational illnesses in the national parks.
The National Park Service’s Reference Manual-83A states that “within the National Park system, U.S. Public Health Service Commissioned Corps officers assigned to the Office of Public Health are the primary resource for responding to infectious disease cases. These Corps Officers are authorized to handle and share identifiable health data in order to address public health issues and reduce or eliminate associated hazards.”
The CDC guidance states that “the Interior Department has jurisdiction over federal lands and natural resources. It employs scientists in its Office of Public Health, and members of the Public Health Service are assigned to the National Park Service for investigations. These staff are knowledgeable about their jurisdictions and should be collaborated with when federal lands are involved in the outbreak investigation.”
HIPAA and Privacy
USPHS Officers assigned from the HHS to the NPS support the National Park Service to prevent disease transmission through risk assessment and follow up of cases of disease occurring and impacting people on federal lands. Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and Privacy Rule, public health officials within the NPS Office of Public Health (OPH) adhere to laws that govern the use of identifiable information collected in order to perform public health surveillance and outbreak investigations for the purpose of preventing and controlling diseases. In order to protect privacy, any information related to an investigation should be shared with the OPH only through secure systems.
Management of Public Health in Concession Facilities
The OPH supports the NPS Commercial Services Program by providing food safety and other operational public health inspections as well as disease surveillance and investigation for concession facilities and operations. These functions are outlined in NPS policy via the Directors Order 83, Public Health, and the NPS Commercial Services Guide. Obligations to support OPH in these functions to protect public health are defined in the Concession contract:
- The concession contract requires the concessioner to comply with Applicable Laws. Applicable laws include Federal, State and local laws, rules, regulations, requirements and policies governing public health and safety (e.g., NPS Director’s Orders and guidance such as those above).
- The concession contract specifies that that the NPS may require the Concessioner to submit “Miscellaneous Report-other reports and data regarding its performance under the Contractor otherwise, including, but not limited to, operational information.” This would include reporting on public health incidents such as those associated with transmissible disease.
- The concession contract operating plan commonly includes a section on operational reporting including requirements for human health illness reporting such as the following: “Information on all human communicable illnesses, whether employees or guests, is to be promptly reported to the Park's Interagency Communication Center at (xxx) xxx-xxxx. This information, along with other information received, must be inspected by the Public Health Service Sanitarian (i.e., public health officer) to help identify outbreaks of illness associated with contaminated water or food sources or caused by other adverse environmental conditions.”
- The concession operating plan also specifies that concessioners must comply with Public Health Program standards including “vector-born disease prevention and response” activities.
OPH consultants may assist by not only providing disease surveillance and collecting reports, but also advising on disease isolation and quarantine plans, mitigation activities, communication plans, and other public health program matters for commercial services in parks. The PHS conducts its oversight and consultation activities in close coordination with park managers and the concessioner and in accordance with the authorities, policies and procedures outlined in the above in a manner that meets all HIPAA and privacy and security requirements.