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Tuberculosis in the Workplace (2001) / Chapter Skim
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4 Comparison of CDC Guidelines and Proposed OSHA Rule
Pages 56-80

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From page 56...
... As this report was being completed in Fall 2000, OSHA had not published the final standard. This chapter summarizes the provisions of the 1994 CDC guidelines for health care facilities and describes points of difference between the guidelines and the 1997 proposed OSHA rule.
From page 57...
... Consistent with OSHA's regulatory responsibilities, the proposed rule is often more specific and directive than the guidelines. Both the CDC guidelines and the proposed OSHA rule were published during a period of change, and as discussed in Chapters 5, 6, and 7, circumstances continue to change.
From page 58...
... Although the recommendations reflect differences between the purposes of correctional facilities and those of health care facilities, many elements are similar to the 1994 guidelines. For example, the discussion of tuberculin skin testing and follow-up for employees is consistent with the 1994 guidelines, except that no category of prison worker is singled out for retesting more often than once a year.
From page 59...
... PROPOSED OSHA RULE ON OCCUPATIONAL EXPOSURE TO TUBERCULOSIS OSHA's mission, described in Chapter 3, differs from that of CDC. In addition, its rules must meet statutory, judicial, and administrative criteria that do not apply to CDC guidelines.
From page 60...
... The rest of this section briefly reviews differences in the settings and people covered by the CDC guidelines and the proposed OSHA rule. The remaining sections focus on differences between the exposure control measures described in the guidelines and those in the proposed rule.
From page 61...
... In a presentation to the committee, OSHA staff suggested that the final rule is likely to cover tuberculosis and HIV-AIDS clinics explicitly. The proposed OSHA rule also does not cover physicians' offices unless high-hazard procedures are performed there.
From page 62...
... The proposed OSHA rule would provide certain job and financial protections for employees with suspected or confirmed infectious tuberculosis that are not provided for in the CDC guidelines. These are described below in the section on administrative controls.
From page 63...
... The following discussion does not cover the 1992 CDC guidelines for those serving homeless people. The 1997 proposed OSHA rule would require homeless shelters to follow essentially the same procedures required for correctional facilities and hospitals that refer rather than treat people with suspected or confirmed tuberculosis.
From page 64...
... of treatment 3. Analyzing worker tuberculin skin test conversions by work area or category NOTE: The proposed OSHA rule would not require assessment of laboratory results, data on drug resistance, medical records, or data on skin test conversions.
From page 65...
... Assisting in investigations of tuberculosis exposure and transmission NOTE: The proposed OSHA rule would require reporting of cases of occupational tuberculosis infection and disease to OSHA, but it does not explicitly require coordination with public health authorities. NOTE: The proposed OSHA rule includes a variety of additional recordkeeping requirements related to employee medical records, medical surveillance, employee training, engineering controls, confidentiality, record availability and transfer, and other matters.
From page 66...
... 17~. The risk assessment described in the 1997 proposed OSHA rule calls for the use of county-level tuberculosis cases without reference to a facility's service area.
From page 67...
... Protocol for conducting a tuberculosis risk assessment in a health care facility. PPD = purified protein derivative; HCW = health care worker; and TB = tuberculosis.
From page 68...
... Thus, the 1997 proposed OSHA rule does not provide for analysis of data on skin test conversions either in identifying low-risk settings or in developing or revising exposure control plans. However, in the list of issues on which it invites comments, OSHA does inquire about the benefits of requiring such analyses and the specific type of analysis that the agency might require.
From page 69...
... CDC, however, advises that two-step testing can be discontinued for the minimal-risk category if experience shows little or no boosting. Except for the facilities that meet the three criteria listed above, the proposed OSHA rule would require facilities to identify employees whose duties could be reasonably anticipated to bring them into contact with people who have suspected or confirmed infectious tuberculosis or with M
From page 70...
... .CDC has accepted the recommendation and has begun the process of considering revisions to the testing and other recommendations of the 1994 guidelines. Baseline Testing The 1994 CDC guidelines describe baseline skin testing at hiring as optional for its category of minimal-risk facilities, but a footnote states that it "may be advisable so that if an unexpected exposure does occur, conversions can be distinguished from positive skin test results caused by previous exposures" (CDC, 1994b, p.
From page 71...
... Unlike the 1994 CDC guidelines, the proposed rule does not provide that immunocompromised workers be offered the voluntary opportunity of reassignment to work involving a low risk of exposure to tuberculosis. The proposed OSHA rule would also require employers to cover the costs of skin tests, respirators, and similar services or equipment.
From page 72...
... The 1997 proposed OSHA rule would require employers to develop a written tuberculosis control plan that included procedures for the prompt identification of individuals with suspected or confirmed infectious tuberculosis. OSHA's commentary on the proposed rule notes that procedures will likely vary for different employers.
From page 73...
... on How Proposed OSHA Rule Differs 73 Identifying Individuals with Suspected or Confirmed Infectious Tuberculosis NOTE: In general, the proposed OSHA rule provides less detailed specification of processes for identifying, diagnosing, and treating individuals with tuberculosis.
From page 74...
... Table 4-3 summarizes the engineering controls that the 1994 CDC guidelines recommend for health care institutions that serve people with tuberculosis. The italicized comments highlight differences between the CDC guidelines and the proposed OSHA rule that might affect the effectiveness or the burdensomeness of a final rule.
From page 75...
... Ventilation Requirements General-Use Areas The CDC guidelines include recommendations regarding ventilation of general-use areas. The proposed OSHA rule does not include ventilation requirements for these areas.
From page 76...
... The CDC guidelines recommend that the number of persons entering isolation rooms be "minimal," but they do not specifically mention employees. The proposed OSHA rule would require provisions in an employer's exposure control plan to minimize the number of employees entering isolation rooms and the time that they spend there.
From page 77...
... Fit Testing and Fit Checking of Respirators The 1994 CDC guidelines recommend that workers who wear respirators should undergo an initial fit test to identify an appropriately fitting respirator and that workers be taught to check the fit of the respirator before each use. The guidelines also state that facilities should have respirator protection programs that conform to the 1987 OSHA respiratory protection standard.
From page 78...
... They also note that all employers who use respiratory protection are covered by the thenapplicable OSHA respiratory protection standard. The 1997 proposed OSHA rule includes explicit provisions for: (1)
From page 79...
... Respirator Use Outside Isolation Rooms The 1997 proposed OSHA rule requires respirator use when workers are either transporting unmasked individuals with suspected or confirmed infectious tuberculosis or when they are working outside isolation rooms in areas where such unmasked individuals are confined (e.g., while awaiting transport to another facility)
From page 80...
... In Chapter 7, the committee's assessment of the likely effects of a final OSHA standard examines three areas of difference that could affect its impact. These areas involve tuberculin skin testing, respiratory protections, and methods for assessing facility risk for occupational transmission of tuberculosis and requirements for control measures.


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