Workplace Health and Safety

Tuberculosis (TB), once the leading cause of death in the United States, appeared to be receding into history by the latter part of the 20th century. An unexpected resurgence of TB occurred in the mid 1980’s and early 1990’s. This was fueled by several converging factors:

• the onset of the HIV epidemic
  
  
• increases in tuberculosis cases among foreign-born persons
  
  
• outbreaks in congregate settings (i.e., hospitals, correctional facilities, hospices)
  
  
• delays in recognizing the appearance and transmission of deadly, drug-resistant TB strains that defy traditional treatments

Despite a general decline in TB case rates in the U.S. since 1993, a marked geographic variation in TB case rates persists. This means that workers in different areas of the country face different potential risks. New Jersey is one of the states with a large proportion of people with risk factors for the disease, notably, HIV infection and immigration from countries with a high prevalence of TB. Therefore, workplace TB prevention efforts remain relevant. PEOSH has issued enforceable requirements for preventing occupational exposure to TB.

There is not a specific PEOSH standard for TB. Since 1995, the New Jersey Public Employees Occupational Safety and Health (PEOSH) Program has been enforcing its "Requirements for Preventing Occupational Exposure to Tuberculosis" (updated 11/2005). Under the PEOSH Act's "General Duty Clause" [N.J.S.A. 34:6A-33(a)]. It requires employers to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."

The requirements are based on federal OSHA's 1996 "Enforcement Procedures for Occupational Exposure to Tuberculosis" and the Centers for Disease Control and Prevention's (CDC) "Guidelines for Preventing Transmission of Mycobacterium tuberculosis in Health-Care Facilities, 1994."

Since 1994, CDC has issued additional TB guidelines which apply to public sector settings. The most notable changes have been in the risk categories and frequency of TB skin testing recommended by CDC for workers at risk of exposure.

PEOSH recommends that public sector employers update their TB risk assessments and TB skin testing protocols based on the most recent CDC guidelines that apply to the particular work setting.

“Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005” applies not only to hospitals and long-term care facilities, but to additional outpatient and nontraditional facility-based settings such as emergency medical services agencies and dental care settings.

Other CDC TB Guidelines include:

• Prevention and Control of Tuberculosis in Correctional and Detention Facilities: Recommendations from CDC
• Guidelines for High Risk Settings

The control of employee exposure to TB is to be accomplished through the early identification, isolation, and treatment of persons with TB, use of engineering and administrative controls to reduce the risk of exposure, and the use of respiratory protection.

PEOSH inspections are conducted in response to employee complaints in workplaces where the CDC has identified workers as having greater risk than the general population. In the New Jersey public sector, these include:

• Health Care Facilities
• Correctional Facilities
• Long-Term Care Facilities for the Elderly
• Drug-Treatment Facilities
• Homeless Shelters

A detailed list of the facilities in each high risk category named above is available in Attachment B [pdf 21k] of the PEOSH Requirements for Preventing Occupational Exposure to Tuberculosis.

Inspections include a review of the employer’s plan for employee TB protection which could incorporate infection control, respiratory protection and skin testing programs. Employee interviews and site observations are an integral part of the inspection process.

Each covered facility must have a written protocol for the prompt identification of individuals with suspected or confirmed infectious TB in order to be in compliance with the TB Requirements.

As stated in the revised TB Requirements, all employers who:

have employees working in one of the five categories of covered facilities (refer to Attachment B [pdf 21k] of the TB Requirements);

and

whose employees have potential exposure to the exhaled air of an individual with suspected or confirmed infectious TB disease, or are present during a high-hazard medical procedure performed on an individual with suspected or confirmed infectious TB disease,

should:

• assign responsibility for the TB Infection Control Program;
• conduct a baseline risk assessment;
• conduct periodic risk assessments; and
• develop and implement a written TB Infection Control Program (TB ICP).

The following actions are mandatory under the PEOSH TB Requirements:

• develop a written protocol for the early identification of individuals with suspected or confirmed infectious TB;
• provide medical surveillance for employees (following the latest CDC Guidelines);
• provide case management of infected employees (following the latest CDC Guidelines);
• report cases of TB;
• provide employee education and training;
• implement engineering controls (when required);
• provide employees with and ensure the use of respiratory protection (when required) in compliance with the PEOSH Respiratory Standard (29 CFR 1910.134).