OSHA issues new guidance for TB protection

Compliance directive allows N95 respirator use

An updated compliance directive issued by the U.S. Occupational Safety and Health Administration (OSHA) in Washington, DC, allows hospitals to use the new N95 respirators to protect health care workers against tuberculosis, eliminating the previous requirement for the more expensive and cumbersome high-efficiency particulate air (HEPA) respirators.

The N95 respirators are part of the new system established by the National Institute for Occupational Safety and Health in Washington, DC, for classifying air-purifying particulate respirators.1 The system includes three levels of filter efficiency: 95%, 99%, and 99.97%, allowing hospitals to choose from a broader range of certified respirators. The N95 respirator is the least expensive, and most likely will be the choice of most hospitals for respiratory protection of HCWs who risk exposure to TB. (See Hospital Employee Health, August 1995, pp. 97-100.)

Reuse of disposable respirators is permitted as long as the respirator maintains its structural and functional integrity and the filter material is not physically damaged or soiled.

The directive also identifies the circumstances in which respirator use is required. Those include when:

* workers enter rooms housing patients with suspected or confirmed infectious TB;

* workers are present during performance of high-hazard procedures on patients who have suspected or confirmed infectious TB;

* emergency medical response personnel or others transport, in a closed vehicle, an individual with suspected or confirmed TB.

The new compliance directive (OSHA Instruction CPL 2.106) supersedes a 1993 compliance memorandum, which had been based mainly on 1990 guidelines for preventing the transmission of TB in health care settings issued by the federal Centers for Disease Control and Prevention in Atlanta.2 The CDC revised its guidelines in October 1994,3 and the OSHA compliance directive reflects those revisions.

TB standard proposal due this summer

The directive will remain effective while OSHA works toward formulation of a new TB standard. A proposal is due out sometime this summer, says OSHA spokeswoman Susan Fleming.

Despite federal budget cuts and congressional opposition that so far have stymied promulgation of final standards regulating workplace ergonom-ics and indoor air quality, "getting the proposal out on TB is a top item," Fleming tells HEH. "The top priorities are based both on concerns and what is realistic. Clearly ergonomics and indoor air quality are major concerns, but trying to get [a final standard] out on them at this time is not realistic."

Fleming says the agency anticipates no formal opposition to a proposed TB standard, "but sometimes opposition materializes after you get something formally out there, as opposed to ergonomics, where it materialized before we could even get anything formally out there." (See related story in HEH, July 1995, pp. 85-89.)

Meanwhile, OSHA will continue to inspect for occupational exposure to TB in response to employee complaints, related fatalities or catastrophes, or as part of all inspections conducted in workplaces where the CDC has identified workers as having a greater incidence of TB infection than in the general population. Those workplaces include hospitals where patients with confirmed or suspected TB are treated or to which they have been transported.

Under the compliance directive, hospitals can be cited for violations of the general duty clause of the Occupational Safety and Health Act [Section (5)(a)(1)], which requires employers to furnish employment free from recognized hazards likely to cause death or serious physical harm to employees.

Methods of abating violations of the general duty clause include:

* early identification of individuals with active TB;

* engineering controls;

* medical surveillance of employees, including:

-- initial examinations;

-- periodic evaluations and reassessments following exposures or changes in health;

* case management of infected employees;

* worker education and training.

References

1. U.S. Public Health Service. National Institute for Occupational Safety and Health. Respiratory protective devices; certification requirements. 60 Fed Reg (June 8, 1995):30,336-30,398.

2. Centers for Disease Control. Guidelines for preventing transmission of tuberculosis in health-care settings, with special focus on HIV-related issues. MMWR 1990; 39 (No. RR-17):1-29.

3. Centers for Disease Control and Prevention. Guidelines for preventing the transmission of Mycobacterium tuberculosis in health-care facilities, 1994. MMWR 1994; 43 (No. RR-13):1-132.

[Editor's note: For a free copy of the new compliance directive, send a self-addressed label to the U.S. Department of Labor, OSHA Publications, P.O. Box 37535, Washington, DC 20013-7535. Telephone: (202) 219-4667. Fax: (202) 219-9266.

The directive also is available through the Internet on the World Wide Web at: http://www.osha.gov in the "Other Documents" section under "Directives." It can be accessed by number (CPL 2.106) or by date of issuance (Feb. 9, 1996).] *