How to Obtain TB Compliance

The Occupational Safety and Health Administration (OSHA) estimates that more than 5 million U.S. employees have contracted tuberculosis (TB) while doing their jobs in hospitals, nursing homes and other similar facilities. The protection of workers from TB exposures while at work is the responsibility of OSHA. It has issued standards that apply to high-risk organizations that mandate that there be in place TB exposure-control plans that include employee education, TB testing and the management of all exposures. Each organization is responsible for complying with OSHA's standards for TB compliance. TB compliance mean that all employees receive annual TB prevention training, that all employees receive annual TB tests with appropriate follow-up and that there is a procedure in place to report and manage any accidental exposures.

Instructions

1. Assign responsibility for TB compliance within the organization and appoint a TB compliance committee that will develop further a TB-prevention program and monitor for employee compliance.

2. Review the current OSHA enforcement procedures and compare to organizational policies that are currently in place. Request data for the past two years from human resources to determine TB compliance of employees. Determine which departments or areas within the organization have the least compliant. Request that the managers or directors of those departments become ad hoc members of the TB compliance committee.

3. Develop a TB exposure-control plan based on OSHA guidelines. Include annual education program for all employees; annual TB testing and management of any TB exposures.

4. Provide within the organization's TB exposure-control plan a means for surveillance, preventive therapy and medical treatment when appropriate. Consider the type of business and service provided by the organization and any possible TB exposures that might occur. Businesses at greatest risk are hospitals, prisons, jails, any facility that provides respiratory care or where the patients are HIV-positive or have AIDS , homeless shelters, emergency rooms, laboratories that do clinical research or TB testing, long-term care facilities, drug or alcohol counseling facilities, and companies that make deliveries to any of these facilities.

5. Draft policies and procedures that will implement appropriate work-practice controls and respiratory protection. Request that all employee be fitted with appropriate respiratory protection masks including respirators in high-risk areas.

6. Develop an employee education program that is taught to all new employees at the time of hire and then repeated annually as part of the annual TB compliance program. Include in the education program a description of the organization's TB compliance plan, the means of TB transmission, the symptoms of an active TB infection and the management of an employee accidental exposure.

7. Develop a means for meeting OSHA time- and record-keeping requirements. Include human resources in meetings with the TB compliance committee regarding the responsibility of managing the record-keeping aspect of TB compliance and a means to follow-up with non-compliant employees.

References

• "Infection Control and Hospital Epidemiology": Tuberculosis in the workplace-OSHA's Compliance Experience
• Occupational Safety and Health Administration: Occupational Exposure to Tuberculosis-Proposed Rule and Notice of Public Hearing
• Occupational Safety and Health Administration: Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis